BIR Ruling No. 39-2018

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

Certificate of Tax Exemption No: 039-2018

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

no case earlier than the date of registration of the project with the BOI, pursuant to Executive 2.57.5 (B)(2) of Revenue Regulations No. 2-98, as amended, Muntinlupa City, a project duly registered with the Board of Investments (BOI) under December 2012 or actual start of commercial operations/selling, whichever is earlier, but in Order No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section housing project, Solano Hills, consisting of 990 units located at Villongco St., Brgy. Sucat, withholding tax on its income received directly in connection with its economic and low-cost] Registration No. Identification Number This certifies that PHINMA PROPERTY HOLDINGS CORPORATION, with Tax dated December 26, 2012, for a period of 3 years beginning from is exempt from income tax and creditable

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. Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and

is not covered by this Certificate of Tax Exemption and shall be subject to applicable taxes under the 1997 Tax Code, as amended. The sale of residential units in excess of the 990 units, as well as the 164 parking lots.

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

that the facts are different, then this Certificate shall 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 thisday of JAN 2 4 2018

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K-1-JAC Commissioner of Internal Revenue CAESAR R.DULAY 012745

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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, Solano Hills consisting of 990 units,

located at Villongco St., Brgy. Sucat, Muntinlupa City. Such exemption shall not cover

revenues from units with selling price exceeding P3,000,000.00.

2 The Company is obligated to construct and sell 990 housing units based on the following

schedules/sales revenues:

Year Volume Value (Php)

(No. of Units)

Total 2 1 3 450 0 0 240 300

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. 107081, 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

Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. provided under E.O. 226, within the periods prescribed under R.A. 10708's Implementing

6. The Company shall be constituted as a withholding agent for the government if it acts as

withholding tax, or if it makes payments to individuals or corporations subject to the employer and any of its employees received compensation income subject to compensation 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.

7. 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 th'e 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 exemption or tax incentives and its tax liability, if any, pursuant to Section 235 of the Tax Code ascertaining whether it is complying with the conditions under which it has been granted tax of 1997, as amended.

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Investment Promotion Agencies 1 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by