BIR Ruling No. 653-2017

BUREAU OF INTERNAL RFVFNUF REPUBLIC OF THE PHILIPPINES DEPARIMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: 1

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that BRIA HOMES, INC. with TIN is exempt from income tax and creditable withholding tax on its income received directly in connection with

Santiago, Gen. Trias, Cavite, a project duly registered with the Board of Investments (BO1) its economic and low-cost housing project, Lumina General Trias Phase 1 and Phase 2 - Brgy. Santiago, Gen. Trias, Cavite consisting of 695 housing units located at Brgy. from December 2016 or actual start of commercial operations/selling, whichever is carlicr. under Registration No. dated December 12, 2016, for a period of 4 years beginning

but in no case earlier than the date of registration of the project with the BOl. pursuant to Executive Order No. 226. otherwise known as the "Omnibus Investments Code of 1987" and Sec.2.57.5 (B)(2) of RR No. 2-98. as amended.

Moreover. the sale by the Company of residential lot valued at P1.919.500.00 and below, or house and lot and other residential dwellings valued at P3,199.200.00 and below. is VAT-exempt under Scction 109(1)(P) of the 1997 Tax Code, as amended.

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

that the facts are different. then this Certificate shall be considered null and void.

Issued this. day of DEC : 9 2017

Awo

Commissioner of Internal Revenue CAESAR R. DULAY 011987 K -

Bria Homes. Inc. Page 2 of 2 Date issued (TE NO. 1-19-2017 53-207

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, Lumina General Trias Phase 1 from units with selling price exceeding P3.000.000.00. located at Brgy. Santiago, Gen. Trias, Cavite. Such exemption shall not cover revenues covered by License to Sell No. License to Sell No. house & lot. and Phase 2 - Brgy. Santiago, Gen. Trias, Cavite consisting of 695 housing units, for Phase 2 shall not be sold for more than P1.700.000.00 per for Phase 1 and the 226 housing units covered by Moreover, the 469 housing units

2. The Company is obligated to construct and sell 695 housing units based on the foliowing

schedules/sales revenues:

Total Year C (No. of Units) Volume 2 0 1 251 1 54 Valuc(Php 000)

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.

The Coinpany'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 required to file its 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 Circuiar No. 1-2016 dated September 1. 20 16. tax returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax

6. The Company shall be constituted as a withhotding 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 subiect to the

withholding taxes as source as required under Chapter X1II and Section 57 of the Tax Code of 1997, as amended and inplemented by Reveuue Regulatious (RR) No. 2-98, as amended.

The Company is required to file on or before the 15th day of the fourth month following the ctose of its accounting period of a Profit and Loss Statenent and Batance Sheet with the Annual Information Return under oath, stating its gross income and expenses incurred during the taxable year.

B Finaily, the Company's books of accounts and other pertinent records shall be suhject 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 T'ax