BIR Ruling No. 317-2021

REPUBLK OF THE PHHLIPPINES

DEPARIMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No: 1-i1-317-2021

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

BOI. pursuant to Executive Order (EO) 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. years beginning from "January 2021 or actual start of commercial operations/selling. housing project, WOODCRESS PHASE 4 -- Brgy. Tapia, General Trias, Cavite, consisting of 325 house and lot units used solely for family home or dwelling purposes, located at Brgy. under Certificate of Registration No. whichever is earlier, but in no case earlier than the date of registration of the project with the as amended. Identification Number (TIN) withholding tax on its income received directly in connection with its economic and low-cost Tapia, General Trias, Cavite, a project dulv registered with the Board of Investments (BOI) This certifies that PROPERTY COMPANY OF FRIENDS, INC. with Taxpayer dated December 29, 2020, for a period of 3 is exempt from income tax and creditable

below, or house and lot and other residentiai dwellings valued at P3,199,200.00' and below, is shall only apply to sale of house and lot and other residential dwellings2 valued at VAT-exempt under Section 109(1)(P) of the National internal Revenue Code (Tax Code) of 1997, as amended. Provided, however, that beginning January 01, 2021. the VAT exemption P3.199,200.00 Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

registered with the BOI, if any, including those units used for commercial purposes such as leasing, retail stores, otfices, etc. shall be subject to the payment of appropriate taxes under the Tax Code of 1997, as amended. However, the sale of house and lot units in excess of the 325 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 nct discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of

that the tacts are different, then this Certificate shail 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 H

K I MDT Commissioner of Internal Revenue CAESAR R. DULAY

2Sntle of lot onty.tegardless ot the priee.sIsat Ie subect to VN trtpz Fanuan n) 201 purstant to R No (r003 I As adjusted using the 2010 Consemer Price Index values pursuant to RR N0. 8-2021 dated June t1. 2021.

Woodcress Phase 4 JEM page 2 of 2 D1S5U

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONTHONS

l.T'he exemption from income and creditable withholding taxes covers only income directly attributabie to the revenues generated from the project, WOODCRESS PHASE + - Brgy. Tapia, General Trias, Cavite, consisting of 325 house and lot units used solely for fanily

home or dwelling purposes located at Brgy. Tapia, General Trias, Cavite. Such exemption shall not cover revenues from units with selling price exceeding P2,000,000.00. Mereover, the 325 house and lot units shall not be soid ior more than P1,700,000.00 per house and lot per License to Sell No.

2.T'he enterprise shall observe the following project timetabie:

Activity Period

Hicense/permit/registration from the Land Acquisition Secure necessary August 2018 - February 2020 August 2017

Start of Commercial Operations Site preparation and development Building/House construction overnment/training costs February 2020 - December 2023 ugust 2020 - December 2023 january 2021

3. In the conputation of the project's ITH. interest income from in-house tinancing shall not be

considered as part ot the revenues generated from the registered housing project.

+. 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 irs BOl Registration.

Pursurt to Section t of Republic Act (RA) No. (07083. the Company is required to fHe its tax

Teturns and pay its tax liabilities, on or before the deadline us provided under the t'ax Code of !497. Hs amended. using the electronic systein for filing and payment of taxes of the BIR. it shail file with BOl a complete annual tax incentives report of its income-based tax inceniives. VAT and duty exemptions, deductions. credits or exclusions from the tax base, as may be provided under EO No 226, within the periods prescribed under RA No. 10708's Implementing Rules and Regulations and Hoint Memorandum Circular No. i -2016 dated September i. 2016.

(. The Company shall be constituted as a withholding agent for the government if it acts as empioyer ind any of its employees received compensation income subject to compensation withholding tax.

or if it makes payments to individuats or corporations subject to the withholding taxes as source as r-quired under Chapter Xil1 and Section 57 of the fax Code of' 1097, as amended. and implemented by RR No. 2-98. as amended.

The Company is required to file on or hefore the 15h day of the fourth month tollowing the close

ot its accounting period of a Protit and Loss Suatemeni and Balance Sheet with the Annual Informatien Return under outh. stating its gross incone and expenses incurred during the taxabie year.

8.Tinally, the Conipany's books ot accounts atd other pertinent records shall be subject to periodie

exam:nation by revenue enforcement otfieers of this Bureau for the purpose ot ascertaining whether it is conplying with the conditions under whieh it has heen granted tax exemption or tax incentives tind its tax liability, if any, pursuant to Section 235 of the Tax Code ot (997. as anended.

in Yet i'nitancing Trapaeney in ihe lnenent nd Accounting nf Ti Incentives Administered hyInvestmen :uuuieui