BIR Ruling No. 365-2017

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE Quezon City

Certificate of Tax Exemption No:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that 8990 HOUSING DEVELOPMENT CORPORATION,with Tax

Identification Number (TIN) is exempt from income tax and creditable withholding tax on its income received directly in connection with its economic and low-cost housing project, Urban Deca Homes H. Cortes Brgy. Kasambagan, Cebu City, consisting of 1,400 housing units located at Urban Deca Homes H. Cortes - Brgy. Kasambagan, Cebu City. a project duly registered with the Board of Investments (BOI) under Registration No.

dated October 04, 2016, for a period of 3 years beginning from January 2017 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 Order No. 226. otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B) (2) of Revenue Regulations (RR) 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 National Internal Revenue Code of 1997, as amended.

However, the sale of the 330 parking slots is not covered by this Certificate of Tax Exemption and 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, for all other applicable taxes not discussed 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 AUG 09 2017

1a3a

CAESAR R.DULAY Commissioner of Internal Revenue K-1-VDPM/LMAT T 008525

8990 HOUSING DEVELOPMENT CORPORATION (Urban Deca Homes H.Cortes) CTE NO Date issued 89-2017 3652017

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. Urban Deca Homes H. Cortes -- Brgy Kasambagan, Cebu City, consisting of 1,400 housing units located at Brgy. Kasambagan Cebu City. Such exemption shall not cover revenues from housing units with selling price exceeding P3,000,000.00. Moreover, the 1,400 housing units covered by License to Sell Nos.

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

2 The Company is obligated to construct and sell 1,400 housing units based on the following

schedules/sales revenues:

Year Total 2 3 Volume (No.of Units) 100 488 696 2 Value(Php000)

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. 10708', 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. I-2016 dated September 1, 2016.

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 National Internal Revenue Code of 1997, as amended, and implemented by Revenue Regulations (RR) No. 2-98, as amended.

7. 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

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.

PAGE 2 OF 2