BIR Ruling No. 592-2017

BUREAU OF INTERNAL REVENUE REPUBLIC OF THYPHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: 592-2017

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Makati City. a project duly registered with the Board of Investments (BOI) under Registration date of registration of the project with the BOI, pursuant to Executive Order (E.O.) No. 226. Number income received directly in connection with its project, Oriental Gardens Makati - Lilac Tower' consisting of 568 residential units located at Don Chino Roces Ave. cor. Export Ave.. No. actual start oi' commercial operations/selling, whichever is earlicr, but in no case earlier than the otherwise known as the "Omnibus Investments Code of 1987" and Sec. 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. This certifies that FEDERAL LAND, INC. (the Company), with Tax Identification dated December 18, 2009 for a period of 4 years beginning from October 2011 or , is exempt from income tax and creditable withholding tax on its

below, is VAT-exempt under Section i09(1)(P) of the 1997 Tax Code, as amended. Moreover, any sale by the Company of residential dwellings valued at P3,199,200.00 and

well as of the 153 parking slots shall be subject to the payment of appropriate taxes under the 1997 Tax Code, as amended. The sale of units (residential and commercial) in excess of the 568 residential units as

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

are different, then this Certificate shall be considered null and void. as represented and submitted. However, if upon investigation, the BIR ascertains that the facts This Certificate of Tax Exemption is being issued on the basis of the facts and documents

Issued this day of DEC 1 4 2017

Ao

K-!-RFR Commissioner of Internal Revenue CAESAR R. DULAY 011726

' Change of registered project name from Jasmine Tower' to -Oriental Gardens Makati-l.ilac Tower' per PAG tetter dated 27 October 2011

Federat Land, Inc. CTE No 92-217 Page 2 of 2 Date issued 14-2077

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Oriental Gardens Makati - Lilac Tower, consisting of 568 units, located at Don Chino Roces Ave. cor. Export Ave., Makati City. Such exemption shall not cover revenues from units with selling price exceeding

2 The Company is obligated to construct and sell 568 low-cost mass housing units based on the

foilowing schedules/sales revenues:

Year 2 3 (No. of Units) Volume 188 1 81 1 Value(PhP)

Total 568

3. In the computation of the project's iTH, interest income from in-house financing shall not he 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 (R.A.) No. 107082, the Company is required to file its may be provided under E.O. No. 226, within the periods prescribed under R.A. 10708's incentives, VAT' and duty exemptions, deductions, credits or exclusions from the tax base. as tax returns and pay its tax liabilities, on or before the deadline as provided under the 1997 BIR. It shall file with BOi a complete annual tax incentives report of its income-based tax Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. Tax Code, as amended, using the electronic system for filing and payment of taxes of the

6. The Company shall be constituted as a withholding agent for the government if it acts as of 1997, as amended and implemented by Revenue Regulations (R. R.) No. 2-98. as amended. 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 XI11 and Section 57 of the Tax Code

7. The Company is required to file on or before the 15th day of the fourth month following the close of iis accounting period of a Profit and Loss Statement and Balance Sheet with the Annual Information Returm 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 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.

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