BIR Ruling No. 45-2020

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF FINANCE

BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No 30TL011

CERTIFICATEOFTAXEXEMPTION

TO ALL WHOM IT MAY CONCERN:

home or dwelling purposes, located at Brgy. Manibaug-Paralaya, Porac, Pampanga, a project income received directly in connection with its economic and low-cost housing project, Fiesta Communities Inc. -- Porac II-C, consisting of 122 house and lot units used solely for family duly registered with the Board of Investments (BOD) under Registration No. Number This certifies that FIESTA COMMUNITIES, INC., with Taxpayer Identification is exempt from income tax and creditable withholding tax on its dated September 20. 2018, for a period of 3 years beginning from September 20, 2018 to September Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended. 19, 2021, pursuant to Executive Order No. 226, otherwise known as the "Omnibus Investments

below,or house and lot and other residential dwellings valued at P3,199,200.00 and below,is Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

VAT-exempt under Section 109(1)P) of the 1997 Tax Code,as amended.Provided,however

that beginning January 1,2021,the VAT exemption shall only apply to sale of house and lot and other residential dwellings' with selling price of not more than Two Million Pesos (P2.000,000.00).

The sale of house and lot units in excess of the 122 house and lot units, including those

house and lot units used for commercial purposes, is not covered by this Certificate of Tax

Exemption and shall be subject to applicable taxes under the 1997 Tax Code, 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 ofiANin

asa

CAESAR R.DULAY

K-1-JAC Commissioner of Internal Revenue 02491

Page 2of 2 Fiesta Communities,Inc.-Porac II-C CTE No.BOI-11-2020 Date issued JAN 1 0 207F

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, Fiesta Communities Inc. -- Porac II- C consisting of 122 house and lot units, located at Brgy. Manibaug-Paralaya, Porac, Pampanga. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the 122 house and lot units per HLURB License to Sell No. shall not be sold for more than P1,700,000.00 per house & lot.

2. The enterprise shall observe the following project timetable.

Secure necessary license/permit/registration from the government/training costs Site preparation and development Land acquisition Activity January 2018~ June 2020 September 2017 April 2017 Period

Building/House construction February 2018 ~ January 2021

Start of Commercial Operations September 2018

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

a. Only income generated from the sale of house and lot units (Fiesta Communities Inc. 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. - Porac II-C, Brgy. Manibaug-Paralaya, Porac, Pampanga) with selling price not

b. Interest income from in-house financing shall not be considered as revenues generated

from the registered activity.

A 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.

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.