BIR Ruling No. 634-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

Quezon City

Certificate of Tax Exemption No:

BOI-LEH-634-220

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

Section 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. housing project, Lynville Residences Bauan Phase 2 -- Brgy. As-is, Bauan, Batangas, at Brgy. As-is, Bauan, Batangas. a project duly registered with the Board of Investments (BOI) to Executive Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Identification Number (TIN) withholding tax on its income received directly in connection with its economic and low-cost consisting of 208 house and lot units used solely for family home or dwelling purposes, located beginning from November 2018 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 under Registration No. This certifies that LYNVILLE LAND DEVELOPMENT CORP.1, with Taxpayers dated October 29, 2018, for a period of three (3) years , 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 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 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. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

leasing, retail stores, offices, etc., shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended. registered with the BOI, if any, including those units used for commercial purposes such as However, the sale of house and lot units in excess of the 208 house and lot units

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 NOV 1 0 2020

Commissioner of Internal Revenue waa CAESAR R. DULAY

K- 037331

2 Sale of iot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to Republic Act (RA) Formerly:Lynville Realty & Development Corporation

No. 10963.

LYNVILLE LAND DEVELOPMENT CORPORATION CTE No.: BOI-LEH-34-

(Lynville Residences Bauan Phase 2) Date issued: NOV + -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, Lynville Residences Bauan Phase 2 Brgy. As-is, Bauan, Batangas, consisting of 208 house and lot units used solely for family home

or dwelling purposes, located at Brgy. As-is, Bauan, Batangas. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 208 house and lot units covered by License to Sell No. shall not be sold for more than P1,700,000.00 per

house and lot.

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

a Only income generated from the sale of housing units (Lynville Residences Bauan Phase

2 -- Brgy. As-is, Bauan, Batangas) 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.

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.

Pursuant to Section 4 of Republic Act (RA) No. 107083, the Company is required to file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the National Internal

Revenue Code of 1997, 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 the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016.

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 National Internal Revenue 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 National Internal Revenue Code of 1997,

as amended.

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

Promotion Agencies.