BIR Ruling No. 53-2020

REPUBLICOFTHE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: BOI-LEH-O19-2020

CERTIFICATE OF TAX EXEMPTON

TO ALL WHOM IT MAY CONCERN:

solely for family home or dwelling purposes located at Brgy. Tanauan, Tanza, Cavite, a project October 03, 2017, for a period of 4 years beginning from June 2018 or actual start of Number income received directly in connection with its economic and low-cost housing project (horizontal), 'PHirst Park Homes Tanza Phase 3, consisting of 7641 house and lot units used duly registered with the Board of Investments (BOI) under Registration No. This certifies that TANZA PROPERTIES III INC., with Taxpayer Identification is exempt from income tax and creditable withholding tax on its dated

as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations registration of the project with the BOI, pursuant to Executive Order No. 226, otherwise known No. 2-98, as amended. commercial operations/selling, whichever is earlier, but in no case earlier than the date of

Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below, or house and lot andother residential dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code of 1997, as amended. Provided, however, that beginning January 1,2021, the VAT exemption shall only

apply to sale of house and lot and other residential dwellings2 with selling price of not more

than Two Million Pesos (P2,000,000.00).

The sale of house and lot units in excess of the 764 house and lot units including those house and lot units used for commercial purposes such as leasing, retail stores, offices, etc., are subject to appropriate taxes under the National Internal Revenue Code of 1997, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions of

The Company.is liable, however, for all other applicable taxes not discussed above. applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof.

This Certificate of Tax Exemption is being issued on the basis of the facts and

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.

Issued this__day of JAN 2 4 2020

Me3or

CAESAR R.DULAY

K-1-JAC Commissioner of Internal Revenue 032333

644 lots/units under License to Sell No. 032961 and 120 lots/units under License to Sell No. 032962.

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963.

Tanza Properties III Inc. - PHirst Park Homes Tanza Phase 3 Page 2 of 2 Date issued JAN 2 4 2020 CTE No. BOI-LEH-019-2020

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, PHirst Park Homes Cavite. Such exemption shall not cover revenues from units with selling price Tanza Phase 3 consisting of 764 house and lot units, located at Brgy. Tanauan, Tanza.

exceeding P3,000,000.00. Moreover, the 644 units per License to Sell No. shall not be sold for more than P1,700,000.00 per house and lot package.

2. The Company is obligated to construct and sell 764 house and lot units based on the following schedules/sales revenues:

Year (No. of Units) Volume (Php 000) Value

2 3 324 354 86

Total 764

3. In the computation of the project's ITH, interest income from in-house financing shall

not be considered as part of the revenues generated from the registered housing project.

4.The Company's entitlement 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

Registration.

5 Pursuant to Section 4 of Republic Act (RA) No. 107083, the Company is required to

file its tax returns and pay its tax liabilities, on or before the deadline as provided under

the 1997 Tax Code, as amended, using the electronic system for filing and payment of

taxes of the BIR. It shall file with BOI a complete annual tax incentives report of its income-based tax incentives, VAT and duty exemptions, deductions, credits or exclusions from the tax base, as may be provided under E.O. 226, within periods prescribe under R.A. No. 10708's Implementing Rules and regulations and Joint

Memorandum Circular No. 1-2016 dated September 1, 2016.

6.The Company shall be constituted as a withholding agent for the government if it acts

as employer and any of its employees received compensation income subject to

compensation withholding tax, or if it makes payments to individuals or corporations

subject to the withholding taxes as source as required under Chapter XIII and Section

57 of the Tax Code of 1997, as amended and implemented by Revenue Regulations

(RR) No. 2-98, as amended.

T The Company is required to file on or before the 15th day of the fourth month following

the close of its accounting period of a Profit and Loss Statement and Balance Sheet with

the Annual Information Return under oath, stating its gross income and expenses

incurred during the taxable year.

8 Finally, the Company's books of accounts and other pertinent records shall be subject

to periodic examination by revenue enforcement officers of this Bureau for the purpose

of ascertaining whether it is complying with the conditions under which it has been

granted tax exemption or tax incentives and its tax liability, if any, pursuant to Section

235 of the Tax Code of 1997, as amended.

3 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by

Investment Promotion Agencies.