BIR Ruling No. 346-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: DO1- LEH -0346 - 20 20

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

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 No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. December 27, 2019, for a period of three (3) years beginning from December 2019 or actual housing project, WOODCRESS PHASE 7, consisting of 1,114 house and lot units used solely for family home or dwelling purposes, located at Brgy. Tapia, General Trias, Cavite, a project duly registered with the Board of Investments (BOI) under Registration No. : Identification Number withholding tax on its income received directly in connection with its economic and low-cost This certifies that PROPERTY COMPANY OF FRIENDS, INC., with Tax , is exempt from income tax and creditable dated

that beginning January 1, 2021, the VAT exemption shall apply only to sale of house and lot below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is 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 lots 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 applicable taxes under the 1997 Tax Code, as amended. The sale, however, of house and lot units in excess of the 1,114 house and lot 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

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 ofJUN 2 5 2020

18a

K- Commissioner of Internal Revenue CAESAR R.DULAY 035547

Sale of lot ony,regardesf the price,shall be subject toVAT starting January 1,202 pursuant to RANo.1093.

Property Company of Friends, Inc. CTE No.HO1-LEM -0 346 -20Z

Page 2 of 2 Date issued JUN 2 5 320

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, WOODCRESS PHASE 7 consisting of 1,114 house and lot units used solely for family home or dwelling

purposes, located at Brgy. Tapia, General Trias, Cavite. Such exemption shall not cover

not sell the house and lot units for more than P1,700,000.00 per HLURB License to Sell No. revenues from units with selling price exceeding P2,000,000.00. Moreover, the Company shall 034893.

2.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.

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. 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 the periods prescribed under R.A.-10708's Implementing

Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

5.The Company shall be constituted as a withhoiding 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 at 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.

T 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.

2 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by

Investment Promotion Agencies.