BIR Ruling No. 591-2017

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: 591-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

382 residential units located at Don Chino Roces Ave., Makati City, a project duly registered 2012 for a period of 3 years beginning from August 2015 or actual start of commercial income received directly in connection with its project, Paseo de Roces Tower 1, consisting of with the Board of Investments (BOI) under Registration No. project with the BOI, pursuant to Executive Order (E.O.) No. 226, otherwise known as the Number operations/sclling. whichever is earlier, but in no case earlier than the date of registration of the "Omnibus Investments Code of 1987" and Sec. 2.57.5 (B)(2) of Revenue Regulations No. 2-98 as amended. This certifies that FEDERAL LAND, INC. (the Company), with Tax Identification , is exempt from income tax and creditable withholding tax on its dated December 14.

and below, is VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended. Moreover, any sale by the Company of residential dwellings valued at P3.199,200.00

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liabie, 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

Issucd this. day of DEC 1 4 2017

Me MKo

K-I-RFR Commissioner of Internal Revenue CAESAR R. DULAY 011728

Federal Land, Inc. Page 2 of 2 CTE No. Date issued"12-14-2017 r91-2017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

I The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project. Paseo de Roces Tower i.

consisting of 382 units, located at Don Chino Roces Ave., Makati City. Such exemption shall not cover revenues from units with selling price exceeding

2 The Company is obligated to construct and sell 382 low-cost mass housing units based on the following schedules/sales revenues:

Year 2 (No. of Units) Volume 127 127 128 Value (PhP)

3 Total 382

3 In the computation of the project's ITH, interest income from in-house financing shatl 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 Repubiic Act (R.A.) No. 10708', the Company is required to file

its tax returns and pay its tax iiabilities, 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.0. No. 226, within the periods prescribed under R.A. 10708's Implementing Ruies and Regulations and Joint Memorandum Circular No. i-2016 dated September 1.2016.

6. 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 XIIl and Section 57 of the Tax Code of 1997. as amended and implemented by Revenue Regulations (R.R.) No. 2-98, as amended.

7 The Company is required to file on or before the l 5th 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 liabitity. 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 Promotion Agencies.