BIR Ruling No. 678-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: 672-20-7

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

project, 11.9 MW Koronadal Diesel Power Plant, located at Koronadal City. South Cotabato. as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. Revenues derived from the power generated and sold to the Wholesale income received directly in connection with the sales of electricity of its power generated start of commcrcial operations, 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 Electricity Spot Market (WESM) shall not be entitled to Income Tax Holiday (ITH). a project duly registered with the Board of Investments (BOD) under Registration No. Number dated February 9. 2015, for a period of 6 years beginning from June 26, 2016 or actual This certifies that SUPREME POWER CORPORATION, with Tax Identification is exempt from income tax and creditable withholding tax on its

applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however. to all other applicable taxes not enumerated 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 thc 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 ofFC 2 9_29t7

C

Commissioner of Internal Revenue CAESAR R. DULAY 012183 K-!

Supreme Power Corporation Page 2 of 2 Date issued 12-29--2017 CTE No. 578-2017

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from incoinc and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, 11.9 MW Koronadal Diesel Power Plant, located at Koronadal City, South Cotabato.

2 The Company is obligated to comply based on the following schedules/sales revenues:

Year 3 Generators No. of 1 t Related Capacity per Generator (MW) I I I Capacity Related Total 11.9 11.9 I. Hours per Operating 2,628 2.628 2,628 Year Volume (MWh) Sales (PhP'000) Value Sales

4 1 I.? 11.9 2,628 5 1 .9 2,628

3 The ITH shall be limited only to the reventes generated from the sales of electricity of the 11.9

MW Koronadal Diesel Power Plant. Revenues derived from power generated and sold to the Whoiesaie Electricity Spot Market (WESM) shall not be entited to ITH.

4 The Company's entitlement to ITH for its BOI-registered power generated project is subject to

the compliance with the provisions of the Specific Terms and Conditions of its BO Registration.

5. Pursuant to Section 4 of Republic Act (RA) No. 10708', the Company is required to file its tax

Code, as amended, using the electronic system for filing and payment of taxes of the BIR. t VAT and duty exemptions, deductions, credits or exciusions from the tax base. as may be provided under E.O. 226. within thirty (30) days from the deadlinc for filing of tax returns and payment of taxes. returns and pay its tax liabilities. on or before the deadline as provided under the 1997 Tax shall file with BOl a complete annual tax incentives report of its income-based tax incentives.

The Company shall be constituted as a withholding agent for the government if it acts as cmployer 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 XII and Section 57 of the Tax Code of 1997, as amended and iniplemented by Revenue Regulations (RR) No. 2-98. as amended

The Company is required to file on or before the 15th day of the fourth month following the closebf its accounting period of a Profit and Loss Statement and Balance Sheet with the Annua Information Return under oath, stating its gross income and expenses incurred during the taxable year.

8. Finaliy. the Company's books of accounts and other pertinent records shall be subject to exemption or tax incentives and its tax liability, if any. pursuant to Section 235 of the Tax Code ascertaining whether it is complying with the conditions under which it has been granted tax of 1997, as amended. periodic examination by revenue enforcement officers of this Bureau for the purpose of

Promotion Agencies. An Act Enhancing Transparency in the Management and Accounting of T'ax Incentives Administered hy Investment