BIR Ruling No. 680-2020

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE . DEPARTMENT CF FINANCE

Quezon City

iLEH-680-2020 Certificate of Tax-Exemption No:

DEC 2 q 2O20

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

This certifies that PHIRST PARK HOMES INC., with Taxpayer Identification

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 No. 2-98, as amended. income received directly in connection with its economic and-low-cost housing project, Phirst Park Homes -- San Pablo 1A & 1B, consisting of 4661 house and lot units used solely for family home or dwelling purposes, located at Brgy. San Ignacio, San Pablo City, Laguna, a project duly registered with the Board of Investments (BOI) under Registration No. dated February 04, 2019, for a period of 4 years beginning from February 2019 or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of Number , is exempt from income tax and creditable withholding tax on its

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 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 dwellings2 with selling price of not more than Two Million Pesos (P2,000,000.00). Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

The sale of house and lot units in excess of the 466 house and lot units, including those

by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 units used for commercial purposes such as leasing, retail stores, offices, etc., are not covered

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.

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 DEC 2 9 2020

Masar

K-1-JAC Commissioner of Internal Revenue CAESAR R. DULAY 039062

1 190 lots/units per HLURB License to Sell No. lots/units per HLURB License to Sell No.

2 Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963.

PHirst Park Homes Inc. -- Phirst Park Homes - San Pabio 1A & 1B Page 2 of 2 Date issued _DEC 2 9 2020 CTE No8HH6 a 0 - 2 0_7 0

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

The exemption from income and creditable withiolding taxes covers only income directly attributable to the revenues generated from the project, Phirst Park Homes -- San Pablo 1A & 1B exemption shall not cover revenues from units with selling price exceeding P2.000,000.00. consisting of 466 house and lot units, located at Brgy. San Ignacio, San Pablo City, Laguna. Such Moreover, the 466 house and lot units per HLURB License to Sell Nos. and shall

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

2. The enterprise shall observe the following project timetable.

Activity Period

Land acquisition September 2018 ~ January 2021

Secure necessary license/permit/registration from the government/training costs Site preparation and development October 2018 ~ January 2019 March 2019 ~ October 2019

Building/House construction November 2019 ~ March 2022

Start of Commercial Operations February 2019

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 (Phirst Park Homes -- San Pablo 1A & 1B, Brgy. San Ignacio, San Pablo City, Laguna) with selling price not

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.

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

from the registered activity.

Pursuant to Section 4 of Republic Act (RA)'No. 107083, 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.

6. 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

7.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 Tax Code of 1997, as amended.