BIR Ruling No. 540-2020

REPUBLICOLTHE PIHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: DOL-LE-0540-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

income received directly in connection with its economic and low-cost housing project, Phirst Park Homes -- San Pablo 2A, consisting of 168 house and lot units used solely for family home or dwelling purposes, located at Brgy. San Ignacio, San Pablo City, Laguna, a project June 26, 2019, for a period of 4 years beginning from June 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 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 Number duly registered with the Board of Investments (BOI) under Registration No. amended. This certifies that PHIRST PARK HOMES INC., with Taxpayer Identification , is exempt from income tax and creditable withholding tax on its dated

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

by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered Tax Code, as amended. The sale of house and lot units in excess of the 168 house and lot units, including those

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 of_SEP 2 3

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K-1-JAC Commissioner of Internal Revenue CAESAR R.DULAY 036511

PHirst Park Homes Inc. -- Phirst Park Homes -- Scan Pablo 2A Page 2 of 2 CTE No.boEHD5 40 -20 20 Date issued P 2 32020

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, Phirst Park Homes -- San Pablo 2A. consisting of 168 house and lot units, located at Brgy. San Ignacio, San Pablo City, Laguna. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 168 house and lot units per HLURB License to Sell No. more than P1,700,000.00 per house & lot. shall not be sold for

2.The enterprise shall observe the following project timetable.

Activity Period

Land acquisition September 2018 ~ January 2021 Secure necessary license/permit/registration from the government/training costs October 2018 ~ January 2019

Site preparation and development March 2019~ October 2019

Building/House construction November 2019 ~ March 2022

Start of Commercial Operations June 2019

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

a. Only income generated from the sale of house and lot units (Phirst Park Homes -- San

purposes such as leasing, retail stores, offices, etc. shall be qualified. Pablo 2A, Brgy. San Ignacio, San Pablo City, Laguna) with selling price not exceeding PhP2.0M and used solely for family home or dwelling purposes and not for commercial

b. Interest income from in-house financing shall not be considered as revenues generated

from the registered activity.

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

226, within thirty (30) days from the deadline for filing of tax returns and payment of taxes. exemptions, deductions, credits or exclusions from the tax base, as may be provided under E.O.

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 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.

7.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.