BIR Ruling No. 295-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: O-LEH-0295-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

income received directly in connection with its economic and low-cost housing project, Phirst or dwelling purposes, located at Brgy. San Lucas, Lipa City, Batangas, a project duly registered No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 Park Homes Lipa Phase 1B, consisting of 482 house and lot units used solely for family home with the Board of Investments (BOI) under Registration No. a period of 4 years beginning from July 11, 2018 to July 10, 2022, pursuant to Executive Order (B)(2) of Revenue Regulations No. 2-98, as amended. Number This certifies that PHIRST PARK HOMES INC., with Taxpayer Identification , is exempt from income tax and creditable withholding tax on its dated July 11, 2018, for

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

by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered Tax Code, as amended. The sale of house and lot units in excess of the 482 house and lot units, including those

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_LJUN 0 8 2020

10w30m

K-1-JAC Commissioner of Internal Revenue CAESAR R.DULAY 034115

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

Phirst Park Homes Inc. -Phirst Park Homes Lipa Phase IB Page 2of2 CTENo.DO1-LEH-0295-2020 Date issued _JUN 0 8_2020

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, Phirst Park Homes Lipa Phase 1B consisting of 482 house and lot units, located at Brgy. San Lucas, Lipa City, Batangas. Such

for more than P1,700,000.00 per house & lot. exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 482 house and lot units per HLURB License to Sell No. thall not be sold

2. The enterprise shall observe the following project timetable.

Activity Period

Land acquisition December 2017 - May 2019| Secure necessary license/permit/registration from the government/training costs January 2018 - May 2018

Site preparation and development January 2018 - October 2018

Building/House construction January 2018 - May 2019

Start of Commercial Operations July 2018

3.In the computation of the project's ITH, the following shall apply:

a. Only income generated from the sale of house and lot units (Phirst Park Homes Lipa

Phase 1B, Brgy. San Lucas, Lipa City, Batangas) with selling price not exceeding PhP2.0M and used solely for family home or dwelling purposes and not for commercial

purposes such as leasing, retail stores, offices, etc. shall be qualified.

b. Interest income from in-house financing shall not be considered as revenues generated

from the registered activity.

4.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 thirty (30) days from the deadline for filing of tax returns and payment of taxes.

5. 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.

6.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.

7. 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.

An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Promotion Agencies.