BIR Ruling No. 348-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

Dol-LaH-0348-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

a project duly registered with the Board of Investments (BOl) under Registration No. housing project, MICARA ESTATE TANZA'PHASE 6, consisting of 739 house and lot units Used solely for family home or dwelling purposes, located at Brgy. Sahud Ulan, Tanza, Cavite, withholding tax on its income received directly in connection with its economic and low-cost December 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. Identification Number This certifies that PROPERTY COMPANY OF FRIENDS, INC., with. Tax dated December 18,2019, for a period of three 3years beginning from is exempt fromincometaxand creditable

below, or house and lot and other residential dwellings valued at P3,199,200 and below, is that beginning January 1, 2021, the VAT exemption shall apply only to sale of house and lot (P2,000,000.00). 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 Moreover, the sale by the Company of residential lots 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 applicable taxes under the 1997 Tax Code, as amended. The sale, however, of house and lot units in excess of the 739 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

that the facts are different, then this Certificate shall be considered null and void. documents as represented and submitted. However, if upon investigation, the BIR ascertains This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of _ jUN 2 5 2020

tawsa

CAESAR R.DULAY Commissioner of Internal Revenue

K- 35548 O

Sale of lot only, regardless of the price, shall be subject to VAT starting January I.2021 pursuant to RA No. 10963.

Property Company of Friends, Inc. CTENo.hoj - Lel - 0 3 4 3-.2 3 2.0

Page 2 of 2 Date issued _IUN 2 5 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 the project, MICARA ESTATE TANZA PHASE 6, consisting of 739 house and lot units used solely for family home or shall not sell the house and lot units for more than Pi,700,000.00 per HLURB License to Seil No. 033869. dwelling purposes, located at Brgy. Sahud Ulan, Tanza, Cavite. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the Company

2. 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.

3.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.

4.. Pursuant to Section 4 of Republic Act (RA) No. 107082, 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 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.O.226, within the periods prescribed under R.A.10708's Implementing Rules and Regulations and Joint Memorandum Circular No.1-2016 dated September1,2016.

5... 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 at 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.

6. 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.

7. 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.

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

Investment Promotion Agencies.