BIR Ruling No. 567-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH-0567-2025

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that 8990 HOUSING DEVELOPMENT CORPORATION, with

withholding tax on its income received airectly in connection with its economic and low-cost housing project, Urban Deca Homes -- Tisa 2(Bldg.7 to BIdg. 21) --Brgy.Tisa, Cebu City consisting of 948 residential units used solely for family home or dwelling purposes, located at Brgy. Tisa, Cebu City, a project duly registered with the Board of Investments (BOI) under from January 2019 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 Investments Code of 1987 and Taxpayer's Identification Number Registration No. Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. dated December 13, 2018, for a period of three (3) years beginning , is exempt from income tax and creditable

exemption from VAT shall only apply to sale of house and lot and other residential dwellings? below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the with selling price of not more than P2,000,000.00. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

with the BOI, if any, including the 5583 shared parking slots and 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 National Internal Revenue Code of 1997, as amended. However, the sale of residential units in excess of the 948 residential units registered

: Per Certificates of Registration (COR) and Licenses to Sell (LTS) isued by the Housing and Land Use Regulatory Board (HLURB) as follows:

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to Republic Act (RA) Shared parking slots per LTS Nos. No. 10963. COR No. COR No. COR No! COR No. COR No. COR No. COR No. COR No. COR No. COR No. COR No. COR No. COR No. COR No! COR No. and LTS No. and LTS No. and LTS No. Aand LTS No. And LTS No. and LTS No. and LTS No. and LTS No. and LTS No. and LTS No. and LTS No. and LTS No. and LTS No. and LTS No. Ind LTS No. Total Urban Deca Homes -Tisa 2 (Bldg.14 Urban Deca Homes -Tisa 2(Bldg.15 Urban Deca Homes - Tisa 2 (Bldg. 16 Urban Deca Homes -- Tisa 2 (Bldg. 17) Urban Deca Homes -- Tisa 2 (Bldg. 18) Urban Deca Homes - Tisa 2 (Bldg. 19) Urban Deca Homes -- Tisa 2 (Bldg. 20 Urban Deca Homes -- Tisa 2 (Bldg. 7) Urban Deca Homes -- Tisa 2 (Bldg. 8) Urban Deca Homes -- Tisa 2 (Bldg. 9) Urban Deca Homes -- Tisa 2 (Bldg. 10) Urban Deca Homes -- Tisa 2 (Bldg. 11) Urban Deca Homes -- Tisa 2 (Bldg. 12) Urban Deca Homes -- Tisa 2(Bldg. 13 Urban Deca Homes -- Tisa 2 (Bldg. 21) 948 units 60 units 56 units 60 units 72 units 64 units 64 units 72 units 72 units 72 units 72 units 72 units 60 units 44 units 60 units 48 units and

8990 HOUSING DEVELOPMENT CORPORATION [Urban Deca Homes - Tisa 2 (Bldg. 7 to Bldg. 21) CTE No.: Date issued: BOLLEH- 0cT T ZUz Q567-2820

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

applicable BIR rules and regulations and the Terms and Conditions stated in Annex"A"hereof.

The Company is liable, however, for all other applicable taxes not discussed above.

This Certificate of Tax Exemption is being issued on the basis of the facts and

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.

Issued this day of OCT 0 1 2020

Aaesav

CAESAR R. DULAY Commissioner of Internal Revenue S K-I-LMAT

036865

PAGEYOFR

8990 HOUSING DEVELOPMENT CORPORATION [Urban Deca Homes -Tisa 2(Bldg.7 to Bldg.21 Date issued: CTE No.: OC0 BOI-LEH- 0 5 6 7 - 2 0 2 3

ANNEX "A"

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes (CWT) covers only income directly

attributable to the revenues generated from the project, Urban Deca Homes -- Tisa 2 (Bldg. 7 to Bldg. 21) -- Brgy. Tisa, Cebu City, consisting of 9484 residential units used solely for family home or dwelling purposes, located at Brgy. Tisa, Cebu City. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 948 residential units covered by the above-enumerated Licenses to Sell shall not be sold for more than P1,700,000.00 per unit.

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

a. Only income generated from the sale of housing units [Urban Deca Homes -- Tisa 2 (Bldg.

7 to Bldg. 21) -- Brgy. Tisa, Cebu City] 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.

3 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.

4. Pursuant to Section 4 of Republic Act (RA) No. 107085, the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under the National Internal be provided under E.O. 226, within the periods prescribed under RA No. 10708's Implementing Revenue Code of 1997, as amended, using the electronic system for filing and payment of taxes of Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. 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

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 National Internal Revenue 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 and its tax liability, if any, pursuant to Section 235 of the National Internal Revenue Code of 1997, it is complying with the conditions under which it has been granted tax exemption or tax incentives examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether as amended

4 While the company is obligated to construct 952 residential units, the exemption from income and CWT covers only 5 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Pronotion Agencies. revenues generated from the 948 residential units allowed per Licenses to Sell issued by the HLURB.