BIR Ruling No. 416-2021

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH - 4 1 5 - 2 0 2 :

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

income received directly in connection with its low-cost mass hou sing project (vertical), home or dwelling purposes, located at V. Mapa cor. Valenzuela St.. Sta. Mesa, Manila, a project duly reoistered with the Board of Investments (BOI) under Certificate of Registration March 2013 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 BOI, pursuant to Executive Order (EO) No. 226, otherwise known as the "Omnibus Investmenis Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. Amaia Skies Sta. Mesa -- South Tower, consisting of 902 housing units used solely for family (TIN) (COR) No. This certifies that AMAIA LAND CORP.1, with Taxpay er Identification Number dated March 19, 2013, for a period of three (3) years beginning from is exempt from income tax and creditable withholding tax on its

residential dwellings? with selling price of not more than P3, 199,200.00.3 exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal 01, 202l, the exemption from VAT shall only apply to sale of hcuse and Iot and other below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is 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 12 commercial units and 183 parking slots, including those other 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 housing units in excess of the 902 housit.g units registered with

applicable BIR rules and regulations and the Terms and Conditions st:.ted at the back hereof. The Company is liable, however, for all other applicable taxes not disc.issed above. The grant of tax exemption herein is subject to the compliance with the provisions of

that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigat ion, thie BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this. day of NOV 0 4 2021

Aex,aM

K-1-MDT Commissioner of Internal Revenue CAESAR R. DULAY

t46810

I Formerly: First Communities Realty, Ins. 2 Sale of fot only, regardless of the price, shall be subject to VAT starting January 01, 2021 ursuant to Republic Act (RA) % As adjusted using the 2010 Consumer Price Index values per RR No. 8-2021 dated June 11, 2021 No. 10963.

(Amaia Skies Sta. Mesa -- S -:utl: Tower) AMAIA LAND CORP. CTE No.: Date issued: BO1:LEH.4- 6 - 2-0 21

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption frou income and creditabie withholding taxes covers only income directly with selling price ex :eeding P3,000,000.00. attributable to the re venues generated from the project, Amaia Skies Sta. Mesa -- South Tower, consisting of 902 hoasing units used solely for family home or dwelling purposes, located at V. Mapa cor. Valenzuela St., Sta. Mesa, Manila. Such exemption shall not cover revenues from units

2. The Company is obligated to construct and sell 902 housing units based on the following schedules/sales reve'tues:

Tota! Year ( ( (No. of Units) Volume 565 002 262 T {PhP NNA} Value

3. In the computation of the project's ITH, interest income from in-house financing shall not be considered as part ot the revenues generated from the registered housing project. 4 The Company's en'itlement 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. Joint Memorandum (Circular No. 1-2016 dated September 1, 2016. Pursuant to Section 4 of Republic Act (RA) No. 107084, the Company is required to file its tax 226, within the perio.s prescribed under RA No. 10708's Implementing Rules and Regulations and returns and pay its ta : liabilities, on or before the deadline as provided under the Tax Code of 1997, 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 as amended, using the: electronic system for filing and payment of taxes of the BIR. It shall file with

6 The Company shall he constituted as a withholding agent for the government if it acts as employer

by RR No. 2-98, as ainended. and any of its employ ees 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 Chapier XIII and Section 57 of the Tax Code of 1997, as amended, and irnplemented

7 The Company is required to file on or before the 15th day of the four:h 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 it is complying with the conditions under which it has been granted tax exemption or tax incentives and its tax liability, if ary, pursuant to Section 235 of the Tax Code of 1997, as amended. examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether

+ An Act Enhancing Transp rency in the Management and Accounting of Ta * Incentives Administered by Investmt it Promotion Agencies.

PAGE 2OF 2