BIR Ruling No. 319-2021

REPUBLICOF THE PHHLIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: Pi--3ig 2021

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

BOI, pursuant to "Executive Order (EO)_ No. 226, otherwise known as "the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Reguiations (RR) No. 2-98. withholding tax on its income received directly in connection with its economic and low-cost housing project, WOODCRESS PHASE 8 - Brgy. Tapia, General Trias, Cavite, consisting of 250 house and lot units used solely for family home or dwelling purposes, located at Brgy. under Certificate of Registration No. whichever is earlier, but in no case earlier than the date of registration of the project with the (dentification Number (TIN) Tapia, General Trias, Cavite, a project dulv registered with the Board of Investments (BOl) years beginning from "January 2021 or actual start of commercial operations/selling as amended. This certifies that PROPERTY COMPANY OF FRIENDS, INC. with Taxpayer dated December 29, 2020, for a period of 3 is exempt from income tax and creditable

below, or house and lot and other residential dwellings valued at P3,199.200.00' and below, is shalt only apply to sale of house and lot and other residential dwellings2valued at P3,199,200.00. VAT-exempt under Section l09(1)(P) of the National (nternal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption Moreover, the sale by the Company of residentiai lot valued at P1,919,500.00 and

registered with the BOI. if any. including those units used for coinmercial purposes such as leasing, retail stores, offices, etc. shall be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of house and lot units in excess of the 250 house and lot units

applicable BiR rules and regulations and the Terms and Conditions stated at the'back hereof. The Company is liable, however, for all other appticable taxes not discussed 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 and void. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of

Ca

K I MDT Commissioner of Internal Revenue CAESAR R. DULAY

As cudjusted using the 2010 (onsunter Price Index values pursuant to RR N0. 8-2021 sated Fune +1. 2021 Sale of lot only, regardless of the price. shall he subject to V \ f -tarting January 01. 2021 pursuant to RA No. 10963.

Woodcress Phase 8 "TF M (nge ? of ? Dote issuer

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption fron income and creditable withholding taxes covers oniy income directly shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 250 attributable to the revenues generated from the project, WOODCRESS PHASE 8 - Brgy home or dwelling purposes located at Brgy. Tapia, General Trias, Cavite. Such exemption house and lot units shall not be sold for more than P1,700,000.00 per house and lot per License to Tapia, Gencral Trias, Cavite, consisting of 2s0 house and lot units used solely for family

Sell No.

2. The enterprise shall observe the following project timetabie:

Activity Period Land Acquisition August 2017

[ Start of Commerciai Operations government/training costs Site preparation and development Buiiding/House construction Secure necessary Iicense/permitiregistration from the February 2020 - December 2024 August 2020 - December 202+ August 2018 - February 2020 January 2021

3. In the computation of the project's tTH, interest incotme trom in-house rinancing shall not be considered as part of the revenues generated fron the registered hiousing project.

+. The Company's entitlement to IfH for its Boi-registered housing project is subject to the

compliance with the provisious ot the Specific Terms and Conditions of hs BOl Registration.

:Pursuant to Section + of Republic Act (RA) No. 10708%. the Conpany is required (o fie its tax

relurns and pay its tax liabilities, on or before the deadiine as provided under the Tax Code of 1997. as amended, using the electronic system for fiting and payinent of taxes of the B!R. it shali file with BOl a coinplete annual tax incentives report of its income-based tax incentives, VA T and duty exemptions, deductions. credits or exclusions from the tax base, as may be proviied under EO No. 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Joint Memorandun Circuiar No. I-2016 dated Septemter 1. 2016.

p.The Company shall be constituted as a withhoiding agent for the governinent if it acts as empioyer

and any of its employees received coinpensation income subject to compensation withhofding tax. or if it makes pavments to hudividuais or corporations subiect to the withhoiding taxes as source us teyuired under Chapter X1I and Seetion 57 of the Tax Code of 1997. as amended. and implemented by RR No. 2-98, as amended.

7.The Company is required to tile on or before the +5" day of the fourth month following the close

of its uccounting period of a Protit and Loss Statement and Balance Sheet with the Annual Information Return under oath, stating its gross income and expenses ineurred during the taxable ycar.

2 .T'inally, the Company' books of accounts and other pertinent records shall be suoject so periodie

examination by revenue enforcement otticers of this Bureau for the purpose of ascertaining whether it is counplying with the conditions under which it has been granted tax exernption or tax incentives and its tax tiability, it any- pursuant to Section 235 of the Tax Code of 1997, as amended.

n Nu Tohancing Transparency in the Wnugenent and Accounting of Tav lneentives Aministered hy Tnvestment fhwiioi igLllcicy