BIR Ruling No. 262-2022

CE REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: Bor- leh - 262-2022

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that PRIMA CASA LAND & HOUSES, INCi. with Taxpayer

housing project, Lumina Subic Phase 1, 2 and 3 -- Brgy. Pamatawan, Subic, Zambales withholding tax on its income received directly in connection with its economic and low-cost consisting of 1,385 house and lot units used solely for family home or dwelling purposes, located at Brgy. Pamatawan, Subic, Zambales, a project'duiy registered with the'Board of for a period of 4 years beginning from December 2021 or actual start of commercial Identification Number (TIN) Investments (BOI) under Certificate of Registration No. , is exempt from income tax and creditable dated December 10, 2021

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 (EO) 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.

below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is shall only apply to sale of house and lot"and other residential dwellings2 valued at P3,199,200.003 VAT-exempt under Section 109(1)(P) of the National Intemal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, including those units used for commercial purposes such as leasing, retail stores, offices, etc. shall be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of hoyse and lot units in excess of the 1,385 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 ofMAY :2 7. 2022

By: Commissioner of Internal Revenue CAESAR R. DULAY

K-1-MDT MARISSA Deputy Commissioner egal Group O. cabreros 6885

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 202t pursuant to RA No. 10963 3 As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June 11, 2021. ' Formerly: Lumina Homes, Inc. Officer-in-Charge

Lumina Subic Phase 1, 2 and 3 page 2 of 2 Date issued MAY 2 T ^JZZ CTE No.E01+-- 2 6 '2 202

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1 and The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Lumina Subic Phase i, 2 and 3 -- Brgy. Pamatawan, Subic, Zambales, consisting of 1,385 house and iot units used solely for fami!y home or dwelling purposes located at Brgy. Pamatawan, Subic, Zambales. Such exemption shall not cover revenues from units with selling price exceeding P 1,385 house and lot units covered by Provisional'License to Seli Nos. shall not be sold for more than P per house and lot. Morenver the

2. The enterprise shall observe the following project tiraetable:

Total Project Cost Start of Commercial Operations Site Preparation and Development Building/House Construction Milestone February 2021 Inyestment Cost and Schedule January 2021 -- December 2021 December 2021 December 2025

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 entitiement 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. 107084, the Company is required to file its tax

Joint Memorandum Circular No. 1-2016 dated September 1, 2016. returns and pay its tax liabilities,on or before the deadline as provided under the Tax Code of 1997 as amended, using the electronic system for filing and payment of taxes of the BIR. It shall file with BOI a cornplete annual tax incentives report of its income-based tax incentives, VAT and duty 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and exemptions, deductions, credits or'exclusions from the tax base, as may be provided under EO No.

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.

by'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 Tax Code of 1997, as amended, and implemented

7. The Company is required to file on or before the 15ti.day of the fourth month following the close of its accounting period of a Profit and Loss Statement and Balance Sheet with the Aunual

year. Information Return under sath, stating its gross income and expenses incurred during the taxable

8. Finally, the Company's books of accounts and other pertinent records shall be subject to periodic

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

An Act Enhancing Transparency in the Management and Acco'inting of Tax Incentives Administered by Investment Promotion Agencies.

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