BIR Ruling No. 54-2020

REPUBLICOFTHE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: B0I-LH-020-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

received directly in connection with its low-cost mass housing project, The Manila Residences Tower II -- 23i0 Taft Avenue, Manila, consisting of 865 units used solely for family home beginning from September 7, 2010 to September 6, 20141, 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 (RR) No. 2-98, as amended. or dwelling purposes, located at 2310 Taft Avenue, Manila. a nroiect duly registered with the Board of Investments (BOI) under Registration No. This certifies that CITYLAND, INC., with Taxpayers Identification Number (TIN) is exempt from income tax and creditable withholding tax on its income dated August 23,2010,

below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings? with selling price of not more than P2,000,000.00. exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended. used for commercial purposes such as leasing, retail stores, offices, etc., shall be subject to the units, 3 l auxiliary units, 4 1 office/residential units, and 256 parking slots, including those units (per HLURB License to Sell No. However, the sale of housing units in excess of the 865 units registered with the BOI , the excess is 139 units), as well as the 41 commercial

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 JAN 2 4 202Q

10eecu1 a

CAESAR R.DULAY

K-1-LMAT Commissioner of Internal Revenue 032362

Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. Per Certificates of ITH Entitlement issued by the BOI dated February 25,2011, January 12,2012, January 24, 2013,and March 5.2014.

(The Manila Residences Tower ID) CITYLAND,INC CTE N 202020 Date issued_JAN 2 4 2020

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

l.The exemption from income and creditable withholding taxes covers only income directly located at 2310 Taft Avenue, Manila. Such exemption shall not cover revenues from units with attributable to the revenues generated from the project, The Manila Residences Tower II -2310 Taft Avenue, Manila, consisting of 865 units used solely for family home or dwelling purposes. selling price exceeding P3,000,000.00.

2.The Company is obligated to construct and sell 865 units based on the following schedules/sales revenues:

Year (No. of Units) Volume 311 (PhP'000) Value

2 287

Total 3 865 267

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.

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 Republic Act (RA) No. 107083, the Company is required to file its tax

be provided under E.O. 226, within the periods prescribed under RA No. 10708's Implementing returns and pay its tax liabilities, on or before the deadline as provided under the National Internal Revenue Code of 1997, 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 Rules and Regulations and Joint Memorardum Circular No. 1-2016 dated September 1, 2016.

6. The Company shall be constituted as a withhoiding agent for the government if it acts as employer

and any of its employees received compensation income subject to compensation withholding tax. amended, and implemented by Revenue Regulations (RR) No. 2-98, as amended. 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 National Internal Revenue Code of 1997, as

The Company is required to file on or before the 15th day of the fourth month following the ciose 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.

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 National Internal Revenue Code of 1997,

as amended.

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

Promotion Agencies.

PAGE2OF2