BIR Ruling No. 482-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

O1LFH-0482-2020 Certificate of Tax Exemption No:

TO ALL WHOM IT MAY CONCERN: CERTIFICATE OF TAX EXEMPTION

January 2019 or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the BOI, 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 No. 2-98, as amended, housing project, Fiesta Communities, Inc. -- Mariveles Phase 1A & 1B, consisting of 617 house and lot units used solely for family home or dwelling purposes, located at Brgy. Balon withholding tax on its income received directly in connection with its economic and low-cost Anito, Mariveles, Bataan, a project duly registered with the Board of Investments (BOI) under Registration No. IdentificationNumber This certifies that FIESTA COMMUNITIES INCORPORATED, with Taxpayers dated December 20, 2018, for a period of 4 years beginning from is exempt from income tax and creditable

below, or house and lot and other residential dwellings valued at P3,199,200.00 and below, is that beginning January 1, 2021, the VAT exemption shall only apply to sale of house and lot VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however, and other residential dwellings: with selling price of not more than Two Million Pesos (P2,000,000.00). Moreover, the sale by the Compaty of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, as well as those units used for commercial purposes such as leasing, retail stores, offices, etc., are subject to appropriate taxes under the National Internal Revenue Code of 1997, as amended. The sale, however, of house and lot units in excess of the 6172 house and lot units

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 AUG 2 0 2020

ieam

CAESAR R.DULAY

K-1-JAC Commissioner of Internal Revenue 036320

economic house and lot. 'Sale of lot only, regardless of the price, shall be subject to VAT starting January 1, 2021 pursuant to RA No. 10963. Per HLURB License to SellNo. economic house lot units; Per HLURB License to Sell No.

FIESTA COMMUNITIES INCORPORATED Page 2 of 2 Date issued AUG 2 0 2020 CTENo.O1-LEH-0482-2020

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 Fiesta Comimunities, Inc. -- Mariveles Phase IA & not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 617 house and lot units shall not be sold for more than the maximum selling price indicated in the respective Licenses to Sell issued by Housing and Land Use Regulatory Board (HLURB), to wit: 1B, consisting of 617 units, located at Brgy. Balon Anito, Mariveles, Bataan. Such exemption shall

1A-Economic 1B-Economic Phase License To Sell No. No. of House and lot units per House and Lot Unit Maximum Selling Price 8 8

2. The Company is obligated to construct and sell 617 house and lot units based on the following schedules/sales revenues:

Activity Period

Secure necessary license/permit/registration from Site preparation and development government/training cost Land acquisition June2018-December2019 April 2017 July 2018

Building/House construction September 2018 - August 2022 Start of Commercial Operations January 2019

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.

A -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

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 annuai 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 i, 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 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.

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 liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended.

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

Promotion Agencies.