BIR Ruling No. 483-2020

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

Certificate of Tax Exemption No: D01-LH-0483-2020 AUG 2 0 2020

TO ALL WHOM IT MAY CONCERN: CERTIFICATE OF TAX EXEMPTION

withholding tax on its income received directly in connection with its economic and low-cost housing project, Fiesta Communities, Inc. -- Hermosa Phase 1 and Phase 2 -- Brgy. Balsic, Hermosa, Bataan, consisting of 755 house and lot units used solely for family home or dwelling purposes, located at Brgy. Balsic, Hermosa, Bataan, a project duly registered with the Board of Investments (BOI) under Registration No. 2018-281 dated December 20, 2018, for a period of four (4) years beginning from June 2019/or actual start of commercial as amended. Identification Number 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 (RR) No. 2-98, This certifies that FIESTA COMMUNITIES INCORPORATED with Taxpayers is exempt from income tax and creditable

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

leasing, retail stores, offices, etc., shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended.' registered with the BOI, if any, including those units used for commercial purposes such as However, the sale of house and lot units in excess of the 755 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 0 202

Waawy

K-1-LMAT Commissioner of Internal Revenue CAESAR R.DULAY 036319

1Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to Republic Act (RA) No. 10963.

(Fiesta Communities, Inc. - Hermosa Phase I and Phase 2) FIESTA COMMUNITIES INCORPORATED CTENo.DOL-LEH -0 L 8 3 -20 2 0 Date issued AG 2 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, Fiesta Communities, Inc. - Hermosa solely for family home or dwelling purposes, located at Brgy. Balsic, Hermosa, Bataan. Such Phase I and Phase 2 -Brgy. Balsic, Hermosa, Bataan, consisting of 755 house and lot units used exemption shali not cover revenues from units with selling price exceeding P2,000,000.00. not be soid for more than P1,700,000.00 per house and lot. Moreover, the 755 house and lot units covered by License to Sell Nos. and shall

2.In the computation of the project's ITH, the following shall apply:

a. Only income generated from the sale of housing units (Fiesta Communities, Inc.

commercial purposes such as leasing, retail stores, offices, etc. shall be qualified. Hermosa Phase 1 and Phase 2 -- Brgy. Balsic, Hermosa, Bataan) with selling price not exceeding Php2.0M and used solely for family home or dwelling purposes and not for

b. Interest income from in-house financing shall not be considered as revenues generated from the registered activity.

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. 107084, 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

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 RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 12016. the BIR. It shall file with BOI a complete annual tax incentives report of its income-based tax

5 The Company shall be constituted as a withholding agent for the government if it acts as employer

or if it makes payments to individuals or corporations subject to the withholding taxes as source as and any of its employees received compensation income subject to compensation withholding tax,

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.

6. The Company is required to file on or before the 15th day of the fourth month foilowing 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 National Internal Revenue Code of 1997,

as amended.

2 Fiesta Comtmunities, Inc. - Hermosa Phase l consisting of 516 house and lot units.

3Fiesta Communities, Inc. - Hermosa Phase 2 consisting of 239 house and lot units.

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

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