BIR Ruling No. 588-2020

BUREAU'OF INTERNAL REVENUE REPUBLICOFTHE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate of Tax Exemption No: D0-EH-0588-2020

CERTIFICATE OF TAXEXEMPTON

TO ALL WHOM IT MAY CONCERN:

or dwelling purposes, located at Brgy. San Lucas, Lipa City, Batangas, a project duly registered income received directly in connection with its economic and low-cost housing project, Phirst Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as Number Park Homes Lipa Phase 2A, consisting of 138 house and lot units used solely for family home for a period of 3 years beginning from January 2019 or actual start of commercial project with the BOI, pursuant to Executive Order No. 226, otherwise known as the "Omnibus with the Board of Investments (BOI) under Registration No. operations/selling, whichever is earlier, but in no case earlier than the date of registration of the amended. This certifies that PHIRST PARK HOMES INC., with Taxpayer Identification is exempt from income tax and creditable withholding tax on its dated January 14, 2019

that beginning January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellings' with selling price of not more than Two Million Pesos (P2,000,000.00). 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. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered by this Certificate of Tax Exemption and shall be subject to applicable.taxes under the 1997 Tax Code, as amended. The sale of house and lot units in excess of the 138 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 OCT 0 6 2020

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K-1-JAC Commissioner of Internal Revenue CAESAR R.DULAY 036838 O

I' Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963.

PHirst Park Homes Inc.-Phirst Park Homes Lipu Phase,2A Page 2 of 2 CTENo.OkH0588-2.020 Date issued UCT U 6 ZU2U

TERMS AND CONDITIONS

OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, Phirst Park Homes Lipa Phase 2A

consisting of 138 house and lot units, located at Brgy. San Lucas, Lipa City, Batangas. Such

exemption shall not cover revenues from units with selling price exceeding P2,000,000.00.

Moreover, the 138 house and lot units per HLURB License to Sell No. shall not be sold for

more than P1,700,000.00 per house & lot.

2. The enterprise shall observe the following project timetable.

Activity Period

Land acquisition December 2017~May 2019

Secure necessary license/permit/registration from the government/training costs Site preparation and development November 2018 ~ December June 2018~ August 2018 2018

Building/House construction July 2019~ April 2021

Start of Commercial Operations January 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 Lipa

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

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 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.

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.

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.

An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Proinotion Agencies.

REPUBLIC OF THE PHILIPPINES

BUREAU OF QNTERNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No: NS4-0592-2020

CERTIFICATE OF TAX EXEMPTION

favor of the National Housing Authority (NHA) over the parcels of land described below, to Wit; This certifies that the Deeds of Absolute Sale (DOAS) executed by the Landowners in

Date of Deed of Absolute Sale May 21, 2020 May 21, 2020 May 21, 2020 Banes' Arturo Banes Custodio Castor Heirs of Rodolfo Landowner/s Name of Certificate of Title Original Nols. Area (sq. m.) Aggregate. 57,399 30,658 59,215 Transferred (sq.m.) 43,540 36,189 30,358 Area Ajuy, Iloilo Location

which shall be used for the Ajuy Housing Project, consisting of 1,500 housing units located in the Municipality of Ajuy, Iloilo, a socialized housing project of the NHA under its Typhoon Permanent Housing Program, to be undertaken by Eddmari Construction and Trading, are not subject to creditable withholding tax/capital gains tax, documentary stamp tax and value-added tax pursuant to Sections 19 and 20 of Republic Act (RA) No. 7279 and Section 109 (1) (P) of the Tax Code of 1997, as amended.

effect transfer of the land titles in the name of the NHA without the Certificate Authorizing documentary requirements provided under RMO No. 15-2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR. intended and shall not be construed as giving authority to the concerned Register of Deeds to Registration (CAR) issued by this Bureau. In this regard, this CTE, together with the It is, however, understood that this Certificate of Tax Exemption (CTE) is never

be applied or are being applied to a socialized housing project pursuant to RA 7279. the Register of Deeds having jurisdiction over the properties, to the effect that the same are to Upon application for exemption, a lien on the titles of the lands shall be annotated by

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 OCT 1 5 2020

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K-1 Commissioner of Internal Revenue CAESAR R. DULAY 037042 C

This Certificate of Tax Exemption does not cover exemption from estate tax, if any, due on the estate of Rodolfo Banes.