BIR Ruling No. 263-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No: DO(-LH-0263-2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

No. 2019-212 dated October 25, 2019, for a period of 3 years beginning from November 2019 the date of registration of the project with the BOI, 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 No. 2-98, as amended. housing project, Paragon Village Phase 3, consisting of 737 house and lot units used solely for family home or dwelling purposes, located at Brgys. San Agustin & Cabuco, Trece Martires or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than Taxpayer Identification Number withholding tax on its income received directly in connection with its economic and low-cost City, Cavite, a project duly registered with the Board of Investments (BOI) under Registration This certifies that THE NEW APEC DEVELOPMENT CORPORATION, with , is exempt from income tax and creditable

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

house and lot units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 Tax Code, as amended. The sale of house and lot units in excess of the 737 house and lot units, including those

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

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

Issued this day of_MAY 2 6 2020

K-1-JAC Commissioner of Internal Revenue Noeawa CAESAR R.DULAY 035051

G

Sale of lot nly, regardlessof the price, shall be subject toVAT starting January 01,2021 pursuant toRANo.10963.

**Paragon Village Phase 3 The New Apec Development Corporation Page 2 of 2 CTENo.O-LtH -0263 -2020 Date issued_MAY 2 6_202

TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION

1. The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, Paragon Village Phase 3 consisting of

737 house and lot units, located at Brgys. San Agustin & Cabuco, Trece Martires City, Cavite.

Such exemption shall not cover revenues from units with selling price exceeding

P2,000,000.00. Moreover, the 737 house and. lot units per HLURB License to Sell No. 034854

shall not be sold for more than P1,700,000.00 per house & lot package.

2 The enterprise shall observe the following project timetable.

Activity Period

Land acquisition January 2015 to July 2015

Secure necessary license/permit/registration from the government/training costs Site preparation and development September 2016 to June 30,2021 August 2015 to September 2019

Building/House construction August 2016 to September 2023

Start of Commercial Operations November 2019

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

Only income generated from the sale of housing units (Paragon Village Phase 3

Brgys. San Agustin & CabucoTrece Martires City Cavite with selling price not

exceeding PhP2.OM 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

4 Pursuant to Section 4 of Republic Act (RA) No. 107082, the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under the 1997 Tax

Code, as amended, using the electronic system for filing and payment of taxes of 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 be provided under E.O. 226, within thirty (30) days from the deadline for filing of tax returns and

payment of taxes..

5. 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.

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.

7. 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.

An ActEnhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Promotion Agencies