BIR Ruling No. 795-2019

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNALREVENUE

Quezo'n City

Certificate of Tax Exemption No:

07.95-2019

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN

This certifies that BELLAVITA LAND CORPORATION, with Tax Identification

income received directly in connection with its low-cost housing project (horizontal), BellaVita - located at Brgy. San Andres, Alaminos, Laguna, a project duly registered with the Board of beginning from March 2013 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 Alarminos, consisting of 506 housing units used solely for family home or dwelling purposes Investments (BOI) under Registration No. Order No. 22.6, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 Nurnber is exempt from income tax and creditable withholding tax on its dated March 5, 2013, for a period of 4 years

(B)(2) of Revenue Regulations No. 2-98, as amended.

Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below. or house and lot and other residential dwellings valued at P3,199,200.00 and below, is VAT-exempt under Section 109(1)(P) of the 1997 Tax Code, as amended; provided, however, that beginning January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellings with selling price of not more than Two Million Pesos (2,000.000.00).

However, the sale of housing units in excess of the 506 housing units registered with BOI, if any, including those units used for commercial purposes such as leasing, retail stores, offices.

etc., shall be subject to the payment of appropriate taxes under the National Internal Revenue Code

of 1997, as amended.

The grant of tax exemption herein is subject to the compliance with the provisions of 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.

This Certificate of Tax Exemption is being issued on the basis of the facts and 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.

Issued this day of _ DEC 17 2019

Aasa

CAESAR R.DULAY Commissioner of Internal Revenue K-1 031388

Sale of lot only,regardless of the price,shall be subject toVAT starting January 1,2021 pursuant to RA No.10963

BELLAVITA LAND CORPORATION(BellaVita-Alaminos) Page 2 of 2 CTE No. 0 79 5 - 2 0 19 Date issued DEC, 1-7 2015

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

L The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, BellaVita - Alaminos consisting of 506 housing units, located at Brgy. San Andres, Alaminos, Laguna. Such exemption shall not cover revenues from units with selling price exceeding P3,000,000.00. Moreover, the 506 housing units per HLURB License to Sell No. shall not be sold for more than P1,250,000.00 per house and lot.

2. The Company is obligated to construct and sell 506 housing units based on the following schedules/sales revenues:

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

1

2 138

3 252

Total 4 508 101

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.

4.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.

5.Pursuant to Section 4 of Republic Act (RA) No. 107082, the Company is required to file its tax provided under E.O. 226, within the periods prescribed under R.A. 10708's Implementing Code, as amended, using the electronic system for filing and payment of taxes of the BIR. It Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax 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

6 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 as 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.

I 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.

8.Finally, the Company's books of accounts and other pertinent records shall be subject to pericdic 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.

2An Act Enhancing Transparency in the Manager esAcministere6bv SSTuen Promotion Agencies