BIR Ruling No. 288-2022

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificat Boi-tE ay Exemption No:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

as amended. Investments Code of 1987" and Section 2.57.5 (E% (2) of Revenue Regulations (RR) No. 2-98 years beginning from December. 2021 withholding tax on its income received directly in connection with its economic and low-cost housing project, Lumina Rosario Phase 1 - Brgy. Quilib; Rosario, Batangas consisting of 667 house and lot units used solely for family home or dwelling purposes, located at Brgy. Quilib, Rosario, Batangas, a project dulv reoistered with the Board &f Investments (BOl) under Certificate of Registration No. whichever is earlier, but in no case:earlier than the date of registration of the project with the BOI, pursuant to Executive Order (EO) Nc. Identification Number (TIN) This certifies that PRIMA CASA LAND & HOUSES, INCl. with Taxpayer or actual start of commercial operations/selling, 226, otherwise known as"the "Omnibus lated December 21, 2021, for a period of 4 is exempt from income tax and creditable

below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is P3,199,200.003. shall only apply to sale of house and lot and other residential dwellings? 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 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 exzess o: the 667 house and lot units

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

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

Issued this day JUN 0 8 2022

K-1-MDT Commissioner of Internal Revenue CAESAR R. DULAY Ifn+ 0517 7 1 O

2 Sale of iot only, regardless of the price, shall be Subject to VAT starting January 01, 202t pursuant to RA No. 10963. 3 A5 adjusted using the 2010 Consumer Price Indax values pursuant to RR No. 8-2021 dated June 1 1, 2021. I Formerly: Lumina Homes, Inc.

CTE NO.BOI-LEH:2 8 8 - 2 .0 2 2

page 2 of 2 Lumina Rosario Phase 1 Date issued. I? 2n??

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

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

attributable to the revenues goneraid from the project, Lumina Rosario Phase 1 -- Brgy. Quilib, Rosario, Batangas, consisting of 667 house and iot units used solely for family home or dwelling purposes located at Brgy. Quilib, Rosaria. Batangas. Such exemption shall not cover revenues from units with selling price exceeding P covered by Provisional License to Sell No. hail not be sold for more than f Moreover, the 667 house and lot units ) per

house and lot.

2. The enterprise shall observe the following project timetable:

Milestone Investment Cost and Schedule

Site Preparation and Developme' . Start of Commercial Operations Building/House Construction Total Project Cost December 2019 -- December 2025 February 2020 -- December 2025 Decemher 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.

A The Company's entitlement to ITH for its BOl-registered housing project is subject to the compliance with the provisions of the Specific Terms ard Conditions of its BOI Registration.

5.Pursuant to Section 4 of Republic Act (RA) No. 10708*, 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. : -2016 dated September I , 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 ainended, and implemented by'RR No. 2-98, as amended.

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 bv revenue enforcement officers of this Bureau for the purpose of ascertaining - vhether 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.

4 An Act Enhancing Transparency in the Management and Accounirg of Tax Incentives Administered by Investment

Promotion Agencies.