BIR Ruling No. 265-2022

REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE Quezon City

DDU Certificate of Tax Exemption No:

301-LEH ; 2...6 5 - 2 0 2 2

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

withholding tax on its income received directly in connection with its economic and low-cost housing project, Lumina Tuguegarao Phase 2 and Phase 3 - Brgy. Caraig, Tuguegarao the Board of Investments (BOl) under Certificate of Registration No. registration of the project with the BOI, pursuant to Executive Order (EO) No. 226, otherwise purposes, located at Brgy. Caraig, Tuguegarao City, Cagayan, a project duly registered with December 21, 2021, for a period of 4 years beginning from December 2021 or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. Identification Number (TIN) City, Cagayan consisting of 427 house and lot units used solely for family home or dwelling This certifies that PRIMA CASA LAND & HOUSES, INCl. with Taxpayer is exempt from income tax and creditable dated

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is shail only apply to sale of house and lot and other residential dwellings2 valued at VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption P3,199.200.003. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, including those units used for commercial 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 427 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 applicable 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 MAY: 2 7 2022

By: Commissioner of Internal Revenue CAESAR R. DULAY

2 Sate of lot only, regardess of the price, shall be subject to VAT starting January 01, 202i pursuant to RA No. 10963. I Formerly: Lumina Homes, Inc. 3 As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June 1 1, 2021. K-1-MDT MArisSA O.cABreROS Deputy Commissioner Officer-in-Charge Legal Group. 08 82 GN

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Lumina Tuguegarao Phase 2 and Phase 3 page 2 of 2 Date issued_MAY.2 722 CTE No. E01-LF-26 5 - 2'0 2

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

l. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, Lumina Tuguegarao Phase 2 and Phase 3 -- Brgy. Caraig, Tuguegarao City, Cagayan, consisting of 427 house and lot units used solely for family home or dwelling purposes located at Brgy. Caraig, Tuguegarao City, Cagavan. Such

shall not be sold for more than P exemption shall not cover revenues from units with selling price exceeding Moreover, the 427 house and lot units covered by Provisional License to Sell Nos. per hot se and lot. Pd

2. The enterprise shall observe the following project timetable:

Milestone Investment Cost and Schedule Site Preparation and Development Start of Commercihl Operations Totat Project Cost Building/House Construction December 2019 - December 2025 February 2020 - December 2025 December 2021

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. 107089, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the Tax Code of 1997. 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 EO No 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September !, 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 'RR No. 2-98, as amended.

7. 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 cath, 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 Bareau 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.

: An Act Enhancing Transparency in the Management and Accouning of Tax Incentives Administered by Investment

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