BIR Ruling No. 480-2020

5 BUREAU OF INTERNAL REVENUE REPUBLIC OP THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of T Empi bOl-Le#-

TO ALL WHOM IT MAY CONCERN CERTIFICATE OFTAX EXEMPTION

solely for family home or dwelling purposes, located at Sitio Pailob, Sambag II, Cebu City, a dated July 19,2018, for a period of four (4 years beginning from July 2018 or actual start of commercial operations/selling, whichever is earlier,but in no case earlier than the date of from income tax and creditable withholding tax on its income received directly in connection with its economic and low-cost housing project, Aspire Homes Riverside in SWU Village Bldg.1 & 2 Sitio Pailob, Sambag Ii,Cebu Cityconsisting of 142 residential units used project duly registered with the Board of Investments (BOI) under Registration No. registration of the project with the BOI,pursuant toExecutive Order (EO) No.226, otherwise known as the Omnibus Investments Code of 1987and Section 2.57.5(B) (2) of Revenue Regulations (RR) No. 2-98, as amended. CORPORATION with Taxpayers Identification Number (TIN) This certifies that COMMUNITY DEVELOPERS AND CONSTRUCTION is exempt

below, or house and lot and other residentiai dwellings valued at P3,199,200.00 and below, is exemption from VAT shall only apply to sale of house and lot and other residential dwellings! with selling price of not more than P2,000,000.00. exempt from value-added tax (VAT) pursuant to Section109 (1) (P) of the National Internal Revenue Code of 1997, as amended.Provided,however, that beginning January 01,2021, the Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

Stores, offices, etc.shall be subject to the payment of appropriate taxes under the National with the BOI, if any, including those units used for commercial purposes such as leasing, retail Internal Revenue Code of 1997, as amended. However, the sale of residential units in excess of the 142 residential units registered

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 02020

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&K-1-LMAT Commissioner of Internal Revenue CAESAR R.DULAY 1036385 Q

Sale of lot only, regardless of the priceshall be subject toVAT starting January 0i,2021 pursuant to Republic Act (RA)

No. 10963.

(Aspire Homes Riverside in SWU Village Bldg. I & 2) COMMUNITY DEVELOPERS AND CONSTRUCTION-CORFORATION CTENO.O-LEH Date issued_AUG 2 220

I The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Aspire Homes Riverside in SWU Village Bldg. 12 Sitio Pailob, Sambag II, Cebu City, consisting of 142 residential units used solely exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 142 residential units covered by License to Sell No. more than P1,700,000.00 per house and lot. for family home or dwelling purposes, located at Sitio Pailob, Sambag II, Cebu City.Such OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS shall not be sold for

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

Only income generated from the sale of housing units (Aspire Homes Riverside in SWU Village Bldg. 1 & 2 --Sitio Pailob, Sambag II, Cebu City) with selling price not exceeding Php2.0M and used solely for family home or dwelling purposes and not for commercial purposes such as leasing, retail stores, offices, etc. shall be qualified.

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. 107082, the Company is required to file its tax

Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. Revenue Code of 1997, as amended, using the electronic system for filing and payment of taxes of be provided under E.O. 226, within the periods prescribed under RA No. 10708's Implementing returns and pay its tax liabilities, on or before the deadline as provided under the National Internal 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

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

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.

Finally, the Company's books of accounts and other pertinent records shall be subject to periodic 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, examination by revenue enforcement officers of this Bureau for the purpose of ascertaining whether

as amended."

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

Promotion.Agencies.

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