BIR Ruling No. 488-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: 01-LH-0488-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that CITY AND LAND DEVELOPERS, INC., with Taxpayer IdentificationNumber is exempt from income tax and creditable

withholding tax on its income received directly in connection with its low-cost mass housing project (vertical), North Residences, consisting of 522 housing units used solely for family home or dwelling purposes, located at EDSA cor. Lanutan Alley, Brgy. Veterans Village, Quezon City, a project duly registered with the Board of Investments (BOI) under Registration No. dated July 25, 2014, for a period of 3 years beginning from September 2014 or

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 actual start of commercial operations/selling, whichever is earlier, but in no case earlier than Revenue Regulations No. 2-98, as amended.

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

27 commercial units and 151 parking slots)2, including those units used for commercial purposes such as leasing, 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 house and lot units in excess of the 522 housing units (18 residential 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

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

Issued this day of AUG 2 0 2020

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K-1-JAC Commissioner of Internal Revenue CAESAR R.DULAY 036396

2 Per HLURB License to Sell No. 1 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 151 parking slots are authorized for sale. 540 residential units,27 commercial units 8 auxiliary,2 retail, 17 storage and