BIR Ruling No. 654-2017

BUREAU OF INTERNAL REVENUE REPUBHKC OF THE PHLPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: 654-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987". housing project, North Fairway Homes Batch C. consisting of 766 units located at Sitio Pastol, Brgy. Muzon, San Jose Del Monte, Bulacan, a project duly registered with the Board of Investments (BOl) under Registration No. years beginning from March 2016 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 Identification Number withholding tax on its income received directly in connection with its economic and low-cost This certifies that BORLAND DEVELOPMENT CORPORATION, with Tax is exempt from income tax and creditabic dated March 3, 2016, for a period of 3

below, or housc 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. Moreover, the sale by the Company of residential lot valued at P1.919.500.00 and

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof The Company is liable, however, to all other applicable taxes not enumerated above. The grant of tax exemption herein is subject to the compliance with the provisions of

that the facts are different, then this Certificate shail he 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-DEC 1 9 2017

As

Commissioner of Internal Revenue CAESAR R. DULAY 011934 K-I-JAC

Borland Development Corporation Page 2 of 2 CTE No. Date issued_12-19-2017 634-2017

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, North Fairway Homes Batch C consisting of 766 units, tocated at Sitio Pastol, Brgy. Muzon. San Jose Del Monte, Bulacan. Such exemption shall not cover revenues from units with selling price exceeding P3.000.000.00.

2 The Company is obligated to construct and sell 766 housing units hased on the following

schedules/sales revenues:

Year 2 (No. of Units) Volume 230 306 Value(Php 000)

Total 230 766

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.

4. 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.

5. Pursuant to Section 4 of Republic Act (RA) No. 10708', the Company is rcquired to file its tax

returns and pay its tax liabitities, on or before the deadline as provided undcr the 1997 Tax Code, as amended, using the electronic system for filing and payment of taxes of the BiR. It shall file with BOl 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.

6. 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 as source as required under Chaptcr X1II and Section 57 of the Tax Code of 1997, as amended and implemented by Revenue Regularions (RR) No. 2-98, as amended.

7. The Conpany is required to file on or before the 15" 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 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 T'ransparency in the Management and Accounting of Tax Incentives Administered hy Investment Promotion Agencies.