BIR Ruling No. 289-2022

BUREAU OF INTERNAL REVENUE REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE Quezon City

Certificate o. BO}-LEH-2 8`9 1 Exemption No:

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

December 2021 or actual start of commercial operations/selling, whichever is earlier, but in no Order (EO) No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section units used soiely for family home or dwelling purposes, located at Brgy. Quisao, Pililla, Rizal, case earlier than the date of registration of the project with the BOI, pursuant to Executive 2.57.5 (B) (2) of Revenue Regulations (RR) No. 2-98, as amended. housing project, Lumina Pililla -- Brgy. Quisao, Pililla, Rizal consisting of 881 house and lot a project duly registered with the Board of Investments (BO1) under Certificate of Registration No. Identification Number (TIN) withholding tax on its income received directly in connection with its economic and low-cost This certifies that PRIMA CASA LAND & HOUSES, INCl. with Taxpayer ' dated December 21, 2021, for a period of 4 years beginning from is exempt from income tax and creditable

shall' only apply to sale of house "and iot" and other residential "dwellings2 valued at below, or house and lot and Other residentiai dweilings valued at P3,199,200.00 and below, is 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption P3,199,200.003 VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code (Tax Code) of Moreover, the sale by the Company c&-rsidential 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, offices, 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 881 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

documents as represented and submitted. "However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall pe considered null and void. .This Certificate of Tax Exemption is being issued on the basis of the facts and

Issued this day of_Jti f : 2JZ

Commissioner of Internal Revenue CAESAR R.DULAY

K-1-MDT 051778

2 Sale of io only, regardlss of the price, shall be subjest to VAT strting January 01, 2021 pursuant to RA No. 10963 3 As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June l1, 2021. I Formerly: Lumina Homes, Inc.

CTENo. 1o1-LEH-: : 3.- 2 C2 : Lumina Pililla page 2 of 2 Date issued JHN_I: 2022

TERMS AND CONDITIONS OF THE CERHIFICATE OF TAX EXEMPTION

The exemption from income and creditable withholding taxes covers only income directly

attributable to the revenues generated from the project, Lumina Pililla -- Brgy. Quisao, Pililla.

Rizal, consisting of 881 house and lot units used solely for family home or dwelling purposes

located at Brgy. Quisao, Pililla. Rizal. Such exemption shall not cover revenues from units with

selling price exceeding 1 Provisional License to Sell No. shall not be sold for more than P Moreover, the 881 house and lot units covered by Her house and

Iot.

2 The enterprise shall observe the following rroject timet: ble:

Site Preparation and Development Building/House Construction Start of Commercial Operations Milestone Decermber 2019 --December 2025 February 2020 -- December 2025 Investment Cost and Schedule Decemher 2021 Total Project Cost

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 :o file its tax

returns and pay its tax liabilities, on or before the deadline as provided under the Tax 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 ncer-'ves report of its income-based tax incentives, 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

Joint Memorandum Circular No. 1-2016 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 Tax Code of 1997. as amended. and implemented by'RR No. 2-98, as amended.

7. The Company is required to file on or be : * the 15 day of the fourth month following the close

of its accounting period of a Profit ana Loss Statement and Balance Sheet with the Annual

Information Return urder 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 tr:s Bareau for the purpose of ascertain'rg whether it is complying with the condition's under which in :ras been granted tax exemption or tax incentives and its tax liability, if any, pursuant to Section 235 of the Tax Code of 1997, as amended.

An Act Enhancing Transparency in the Management and Accounting of Tax Incent:ves Administered by Investmert Promotion Ager.cies.