BIR Ruling No. 363-2019

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No. 0363-201

CERTIFICATE OF TAX EXEMPTION

TO WHoM It MAY COnCErN:

pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of located at Chir.^ Rorec Ave. cor. Javier St., Pio del Pilar, Makati City, a project duly regitered with the Board of Investments (BOI) under Registration No. a period of 4 years beginning from January 2011 or actual start of commercial operation/selling. whichever is earlier. but in no case earlier that the date of registration of the project with the BOI. directly in connection with its iow-cost mass housing project, The Oriental Place -- Pio del Pilar, Makati City, consisting of 407 residential units used solely for family home or dwelling purposes] 1987" and Section 2.57.5(B)(2) of Revenue Regulations 2-98, as amended. This certifies that FEDERAL LAND, INC., with Tax Identification Number (TIN) -000. is exempt from income tax and creditable withholding tax on its income received .7 dated August 15, 2008, for

or house and lot and other residential dwellings valued at P3, 199,200.00 and below, is VAT-exempt dwellings' with selling price of not more than Two Million Pesos (P2.000,000.00). under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however, that beginning) January l. 2021, the VAT exemption shall only apply to sale of house and lot and other residentiat Moreover, the sale by the Company of residential lots vaiued at P1,91 9,500.00 and below.

as the 5 commercial units and 148 parking slots, shall be subject to payment of appropriate taxes the BOI, if any (per HLURB License to Seif No under the National Internal Revenue Code of 1997. as amended. The sale, however. of housing units in excess of the 407 residential units registered with , the excess is 255 residential units) as wefl

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

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 documents

Issued this day of JUN 2 7 2019

1alm5 c

Commissioner of Internal Revenue CAESAR R. DULAY

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: Sale of lot only. regardies of the price. shali be subject to VAT starting January 1. 2021 pursuant to RA No 10963.

Page 2 of 2 Federal Land Inc. -- The Oriental Place Date:iued JUN 2 7 2019 CTENO. 0 3 6 3 - 2 3 : 9

TERMS AND CONDITIONS. OF THE CERTIFICATE OF TAX EXEMPTION

The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, The Orientai Place -- Pio det Pilar. Makati City, consisting of 407 residential units used solely for family home or dwelling purposes located at Chino Roces Ave. cor. Javier St., Pio de[ Pilar, Makati City.

The Company is obligated to construct and sell 407 housingiunits based on the following:

Y ear Total 2 (No. of Units) Volume 281 [26 4 P603.144,560 416.421.991 (PhP)(000) 186,722.579 Vaiue

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 from its BOI-registered housing project is subject to the

compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

Pursuant to Section 4 of the Republic Act (RA) No. 107082, the Company is required to fite its tax returns and pay their tax fiabilities. on or before thel 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.

1 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

withhoiding 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 No. 2-98, as amended.

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.

8 Finally. the Company's books of accounts and other pertinent records shall be subject to periodic examination by revenue enforcernent officers of this Bureau for the purpose of

ascertaining whether it has been complying with the conditions under which it has been granted tax exemption or tax incentives and its tax fiability. if any, pursuant to Section 235

A Of the Tax Code of I 997. as amended.

E

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

Investment Promotion Agencies.