BIR Ruling No. 344-2020

REPUBLICOF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No.

DO1-LEH-0344-2020

CERTIFICATE OF TAX EXEMPTION

TO WHOM IT MAY CONCERN:

project (vertical), One Taft Residences 1939 Taft Avenue, Malate, Manila, consisting of 969 housing units used solely for family home or dwelling purposes located at 1939 Taft Avenue, Malate, Manila, a project duly registered with the Board of Investments (BOI) under Registration No. 2014-112 dated July 25, 2014, for a period of 3 years beginning 01 January 2016 to 31 December 20181, 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 2-98, as amended. withholding tax on its income received directly in connection with its low-cost mass housing Identification Number (TIN) This certifies that CITY & LAND DEVELOPERS, INCORPORATED, with Tax is exempt from income tax and creditable

or house and lot and other residential dwellings valued at P3, 199,200.00 and below, is VAT-exempt January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellings2 with selling price of not more than Two Million Pesos (P2,000,000.00). under Section 109(1)(P) of the 1997 Tax Code, as amended. Provided, however, that beginning Moreover, the sale by the Company of residential lots valued at P1,919,500.00 and below,

be subject to the regular taxes under the National Internal Revenue Code of 1997, as amended. including those units used for commercial purposes, such as leasing, retail stores, offices, etc., shall BOI, if any (per HLURB License to Sell No. office/ residential units, 64 residential/auxiliary units, 25 commercial units and 202 parking slots. The sale, however, of housing units in excess of the 969 housing units registered with the , the excess is 65 units), as well as the 22

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

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 documents

Issued thisday ofJUN 2 5 2020

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K-1/s18-1315 Commissioner of Internal Revenue CAESAR R.DULAY 035464

Per BOI Certificate of ITH Entitlement CE No.2017-000089 issued on January 25,2017 at Makati City

Page 2 of 2 City & Land Developers Incorporated -- One Taft Residences CTENo.PL-LH-O344-220 Date issued JUN 2 5 2020

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

* The exemption from income and creditable withholding taxes covers only income directly be covered by ITH. attributable to the revenues generated from the project, One Taft Residences consisting of 969 residential units used solely for family home or dwelling purposes located at 1939 Taft Avenue, Malate, Manila. Revenues from units with selling price exceeding Php3.0M shall not

2 The Company is obligated to construct and sell 969 housing units based on the following

schedules/sales revenues:

Year (No. of Units) Volume Value (P'000)

Total 3 2 969 324 323 322 1,630,203 489,628 545,620 594,955

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.

The Company's entitlement to ITH from its BOI-registered housing project is subject to the compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

5 Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. under E.O.226, within the periods prescribed under R.A. 10708's Implementing Rules and Pursuant to Section 4 of the Republic Act (RA) No.107084, the Company is required to file its Code, as amended, using the electronic system for filing and payment of taxes of the BIR. It shall and duty exemptions, deductions, credits or exclusions from the tax base, as may be provided tax returns and pay their tax liabilities, on or before the deadline as provided under the 1997 Tax file with BOI a complete annual tax incentives report of its income-based tax incentives, VAT

6 The Company shall be constituted as a withholding agent for the government if it acts as employer tax, or if it makes payments to individuals or corporations subject to the withholding taxes at and any of its employees received compensation income subject to compensation withholding source as required under Chapter XIII and Section 57 of the Tax Code of 1997, as amended and implemented by Revenue Regulations 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 year. Information Return under oath, 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 examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether it has been 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.