BIR Ruling No. 273-2020

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE

AO0 Quezon City

DD

Certificate of Tax Exemption No:

BOI-LEH-0273-20 2 0

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

withholding tax on its income received directly in connection with its economic and low-cost housing project vertical,Field Residences Building Sitio Balibatar,Brgy.Manuyo Uno, Las Pinas Cityconsisting of619 housing units ued solely for family home or dwelling purposes, located at Sitio Balibatar, Brgy. Manuyo Uno, Las Pifias Citvi. a project duly commercial operations/selling, whichever is earlier, but in no case earlier than the date of registered with the Board of Investments (BOI) under Registration No. 12,2017, for a period of three 3 years beginning from December2017 or actual start of registration of the project with the BOI, pursuant to Executive Order No.226, otherwise known Identification Number (TIN) as theOmnibus Investments Code of 1987and Section 2.57.5 (B(2) of Revenue Regulations (RR) No. 2-98, as amended. This certifies that SM DEVELOPMENT CORPORATION, with Taxpayers , is exempt from income tax and creditable : dated April

below, or house and lot and other residentiai 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 with selling price of not more than P2,000,000.00. exemption from VAT shall only apply to sale of house and lot and other residential dwellings2 Moreover, the sale by, the Company of residential lot valued at P1,919,500.00 and

appropriate taxes under the National Internal Revenue Code of 1997, as amended. the BOI, if any, as well as the 104 parking slots, including those other units used for commercial purposes such as leasing, retail stores, offices, etc., shall be subject to the payment of However, the sale of housing units in excess of the 619 housing units registered with

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

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. This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this. day of MAY 2 6 2020

1a30ay

Commissioner of Internal Revenue CAESAR R.DULAY

K-1 035087

f nardsfteprichll e subjct tVAT starting January ,2021puruant t epublic Act (A Per Cerrificate of Registration No. 028044 and License to Sell No. 032454 both issued by the Housing and Land Use Reulatory BoardHLURBdatedFebruary22.2017and Augu 242017repectivelyFid Reences Buiing 5 ated at Dr. A.Sano Avenue, Brgy.San Dionio Paraaque City /Barangay Manuy Uno Las Pias ity No. 10963.

SM DEVELOPMENT CORPORATION Field Residences Building 5 CTE No.: Date issued: -MAY 2 6 2020 BOI-LEH -02 7 3 -2 0 20

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

2. The Company is obligated to construct and sell 619 housing units based on the following The exemption from income and creditable withholding taxes covers only income directly attributable to the revenues generated from the project, Field Residences Building 5 Sitio schedules/sales revenues: family home or dwelling purposes, located at Sitio Balibatar, Brgy. Manuyo Uno, Las Piias City. Such exemption shall not cover revenues from units with selling price exceeding P3,000,000.00. Balibatar,Brgy.Manuyo Uno,Las Pinas City, consisting of 619 housing units used solely for

Year Total 3 2 L (No. of Units) Volume 252 340 619 27 (Php'000) 1,623,293 427,458 566,448 629,387 Value

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 RepublicAct(RA) No. 107083, the Company is required to file its tax

incentivesVAT and duty exemptions,deductions, credits or exclusionsfrom 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. 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

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.

The Company is required tofile on or before the 15 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 complyingwith the conditions under which it has been granted taxexemption 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.

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