BIR Ruling No. 674-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENTOF FINANCE BUREAU Q5UNTFRINAL REVENUE eriab f T* Pyugion No PSH-0674-

DEC 2 3 2020

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that CENQHOMES DEVELOPMENT CORPORATION with

creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA) No. 7279 Taxpayers Identification Number (TIN) is exempt from income tax and

a project duly registered with the Housing and Land Use Regulatory Board (HLURB) under Phase 2, consisting of 3111 house and lot units located at Brgy. San Isidro, Rodriguez, Rizal as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated units for residential and dwelling purposes to qualified beneficiaries in East Bellevue Residences of said house and lot units does not exceed P530,000.002per house and lot packages. Certificate of Registration No. July 17, 2016, on its income received directly in connection with sale of socialized house and lot and License to Sell No. provided that the selling price

or house and lot and other residential'dwellings valued at P3,199,200.00 and below, is exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the exemption Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and below,

from VAT shall only apply to sale of house and lot andother residential dwellings3 with selling price of not more than P2,000,000.00.

It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the

properties shall'be subject to DST imposed under Section 196 of the Tax Code of i997, as

amended, based on the consideration contracted to be paid for such realties or on their fair market

value determined in accordance with Section 6 (E) of the same Code, whichever is higher.

Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall

be subject to the payment of appropriate taxes.

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, for 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 DEU 200

1e&M

K-1-MDT Commissioner of Internal Revenue CAESAR R. DULAY 038829

Sale of lot only, regardless of the price, hll be supject toVAT staring January O1,2021 pursuant to RANo.10963 Per License to Sell No. 2 The maximum selling price is pegged at .house and lot units are authorized for sale. per house & lo based on HLURB License to Sell No.

CENQHOMES DEVELOPMENT CORPORATION Page 2 of 2 Date issuedDEC 2 3 2020 CTE No. 0674-2020

o OF.THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, East Bellevue Residences Phase 2 consisting of 311 house and lot units, located at Brgy. San Isidro, Rodriguez, Rizal. Such exemption shall cover revenues from 311 house and lot units with selling price not exceeding P530,000.00 per house and lot packages.

2. The developer shall submit the sworn statement of the buyer that he is eligible as a socialized

housing beneficiary provided under Section 5 (A) of Revenue Regulation (RR) No. 11-97 to the Bureau of Internal Revenue (BIR during the processing of the Certificate Authorizing Registration (CAR) for the transfer of the socialized housing unit.

3.It is understood that the CAR shall only be issued after it is established upon proper verification

by the Revenue District Officer (RDO) concerned that, considering the rules on valuation of real

property, the actual selling price per sale transaction of the house and lot packages in this case

does not really exceed P530,000.00.