BIR Ruling No. 412-2021

3 BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of fax Exemption No:

BOI-LEH- 4 1 2 - 2 0 2 1 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN:

BOI, pursuant to "Executive Order (EO) No." 226, otherwise kno:vn as "the "Omnibus home or dwelling purposes, located at Shaw Bivd. corner Samat"Street. Brgy. Highway Hills. Certificate of Registration (COR) No. Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98. income received directly in connection with its low-cost mass housing project (vertical), Amaia Skies Shaw -- North Tower, consisting of 1,348 housing units used solely for family Mandaluyong City, a project duly registered with the Board of Inv estments (BOI) under (3) years beginning from`March 2015 or actual start_of commercial operations/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the as amended. (TIN) This certifies that AMAIA LAND CORP.1, with Taxpay er Identification Number is exempt from income tax and creditabie :vithholding tax on its dated March 11, 2015, for a period of three

01, 2021, the exemption 'from VAT shall only apply to'sale of house and lot and other residential dwellings2 with selling price of not more than P3,199,200.00.3 below, or house and lot and other residentiai dwellings valued at P3. 1 9.9,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

the BOI, if any, as well as the 17 commercial units and 371 parking slots. including those other units used for commercial purposes such as leasing, retail stores, offices, etc., shali be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of housing units in excess of the 1,348 housir units registered with

applicable BIR rules and regulations and the Terms and Conditions stated at the'back hereof. The Company is liable, however, for all other applicable taxes not discu ssed above. The grant of tax exemption herein is subject to the compliance with the provisions of

documents as represented and submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null und vpid. Issued this This Certificate of Tax Exemption is being issued on the basis of the facts and day of NOV 4 2021

80

K-I-MDT Commissioner of Internal Revenue CAESAR R. DULAY

C48753

2 Sale of iot only, regardless of the price, shall be suhject to VAT starting January 01, 2021 pt.rsuant to Republic Act (RA) + Formerly: Firs: Communities Realty, Inc. 3 As adjusted using the 2010 Consumer Price Index values per RR No. 8-2021 dated June I 1, 2.21. No. 10963

(Amaia Skies Shaw - North Tov'er) AMAIA LAND CORP. Date issued: CTE No. BOL LEH-412 - 2 0 21

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withhoiding taxes cos ers only income directly

attributable to the revenues generated from the project, Amaia Skies $haw - North Tower, consisting of 1,348 htusing units used solely for family home or dwelling : irposes, located at Shaw Blvd. corner Samat Street, Brgy. Highway Hills, Mandaluyong City. S: ch exemption shall not cover revenues from units with seiling price exceeding P3.000,000.00.

The Company is obligated to construct and sell 1,348 housing units based on the following schedules/sales revenues:

Year 1 (No. of Units) Volume 114 (P'000) Value

2 684

Total 3 1,348 550

3. In the computation of the project's ITH, interest income from in-house financi:ig shall not be considered as part ot' the revenues generated from the registered housing project.

4. The Company's en':tlement to ITH for its BOI-registered housing project is subject to the compliance with the provisions of the Specific Terms and Conditions of its BOI Reistration.

5. Pursuant to Section + of Republic Act (RA) No. 107084, the Company is required to file its tax returns and pay its ta x liabilities, on or before the deadline as provided under the Tax (Code of 1997.

as amended, using th & electronic system for filing and payment of taxes of the BIR. It : hall file with BOI a complete anrual tax incentives report of its income-based tax incentives, V T and duty

Joint Memorandum "ircular No. 1-2016 dated September 1, 2016. exemptions, deductions. credits or exclusions from the tax base, as may be provided nder EO No 226. within the periods prescribed under RA No. 10708's Implementing Rules and Reulations and

6. The Company shall !re constituted as a withholding agent for the government if it ac s as employer

and any of its emplovees received compensation income subject to &ompensation w ithholding tax. or if it makes payments to individuals or corporations subject to the withholding tax es as source as required under Chapter XIII and Section 57 of the Tax Code of 1997, as amended, an 1 implemented by RR No. 2-98. as imended.

I The Company is required to file on or before the 15th day of the fourth month follov ing the ciose of its accounting period of a Profit and Loss Statement and Balance Sheet witl the Annual

Information Return uinder oath, stating its gross income and expenses incurred durin ? the taxable year.

Finally, the Compalty's books of accounts and other pertinent records shall be subje :t to periodic examination by reve nue enforcement officers of this Bureau for the purpose of ascertai ning whether it is complying with the conditions under which it has been gr nted tax exemption or : ax incentives and its tax Hiability, if any, pursuant to Section 235 of the Tay Code of 1997, as amen led.

+ An Act Enhancing Trans: arenicy in the Management and Accour ng of Tax Incentives Administer: 1 by Investment

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