BIR Ruling No. 332-2020

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

Certificate of Tax Exemption No: B0I- JUN 1 7 202U

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN: (

Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. housing project,EVISSA DAVAOBrgyMatina PangiTalomo District,Davao City consisting of 390 house and lot units used solely for family home or dwelling purposes, located at Brgy. Matina Pangi, Talomo District, Davao City, a project duly registered with the Board 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 withholding tax on its income received directly in connection with its economic and low-cost 4 years beginning from March 2019 or actual start of commercial operations/selling, Identification Number (TIN) of Investments (BOI) under Registration No. This certifies that JOHNDORF VENTURES CORPORATION with Taxpayers is exempt from income tax and creditable dated March 29, 2019, for a period of

below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is amended. Provided, however, that beginning January 01.2021, the VAT exemption shall only VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code of 1997, as Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

apply to sale of house and lot and other residential dwellings with selling price of not more than P2,000,000.00.

However, the sale of house and lot units in excess of the 3902 house and lot units

registered with the BOI, if any, including those house and lot units used for commercial

purposes such as leasing, retail stores, offices, etc. shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions of

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.

This Certificate of Tax Exemption is being issued on the basis of the facts and

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.

Issued this day of JUN 1.7 2020

Haesaia

CAESAR R.DULAY Commissioner of Internal Revenue

K-1-MDT 035483 9

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

2 Per HLURB License to Sell No. 034042, 390 house and lot units are authorized for sale. 10963.

Johndorf Ventures Corporation -- Evissa Davao Subdivision (page 2 of 2 Date issued CTE No.

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding_ taxes covers only income directly selling price exceeding P2,000,000.00. Moreover, the 390 lots/units covered by License to Sell No. Talomo District,Davao City consisting of 390 house and lot units located at Brgy.Matina Pangi,Talomo DistrictDavao City. Such exemption shall not cover revenues from units with 034042 shall not be sold for more than P1,700,000.00 per house and lot package. attributable to the revenues generated from the EVISSADAVAO Brgy. Matina Pangi e

2.The enterprise shall observe the following project timetable:

from the government/training costs Building/House construction Site preparation and development Land acquisition Secure necessary license/permit/registration Activity January 2018 -- February 2019 2018 May 2018-June2021 May 2018-September 2020 Period

Start of commercial Operations March 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.

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

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

be provided under E.O. 226, within the periods prescribed under RA No. 10708's Implementing incentives, VAT and duty exemptions, deductions, credits or exclusions from the tax base, as may Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

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 National Internal Revenue Code of 1997, as amended, and implemented by Revenue Regulations (RR) No. 2-98, as amended.

7.The Company is required to file on or before the 15th dayof 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 National Internal Revenue Code of 1997. as amended.

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