BIR Ruling No. 50-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: BOI-IEH-016-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

housing project (horizontal), Windsor Heights, consisting of 207 house and lot units used withholding tax on its income received directly in connection with its economic and low-cost solely for family home or dwelling purposes located at Brgy. Mabuhay, General Santos City, a project duly registered with the Board of Investments (BOI) under Registration No. 2017- commercial operations/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the BOI, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations Taxpayers Identification Number 005-975-362-002, is exempt from income tax and creditable 107 dated May 2, 2017, for a period of 4 years beginning from October 2017 or actual start of No. 2-98, as amended, This certifies that MCGREGOR DEVELOPMENT CORPORATION, with

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is that beginning January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellings' with selling price of not more than Two Million Pesos (P2,000,000.00). VAT-exempt under Section 109(1)(P) of the 1997 Tax Code,as amended.Provided,however Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

lot units) including those house and lot units used for commercial purposes such as leasing. registered with the BOI (per HLURB License to Sell No. 031658, the excess is 22 house and retail stores, offices, etc., are not covered by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 Tax Code, as amended. The sale of residential house and lot units in excess of the 207 house and lot units

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. 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.

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 thisday of_ JAN 2 4 2020

1aesam

CAESAR R.DULAY

K-1-JAC Commissioner of Internal Revenue 4 032330

1 Sale of lot only, regardless of the price, shall be subject to VAT starting January 1, 2021 pursuant to R.A. 10963

Page 2 of 2 McGregor Development Corporation/Windsor Heights CTE No.BOI-LEH-O16-2020 Date issued JAN 2 4 2025.

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Windsor Heights, consisting of 207 house and lot units located at Brgy. Mabuhay, General Santos City. Such exemption shall not

cover revenues from house and lot units with selling price exceeding P3,000,000.00.

2 The Company is obligated to construct and sell 207 housing units based on the following

schedules/sales revenues:

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

14

2 64

3 44 4 25 Total 20

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. 107082, 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 the periods prescribed under R.A. 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.

7.The Company is required to file on or before the 15h 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.

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

Investment Promotion Agencies.