BIR Ruling No. 388-2020

REPUBLICOF THE PHILIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Quezon City

Certificate of Tax Exemption No. BOI-LeH-0388 -2020

CERTIFICATE OF TAX EXEMPTION

TO WHOM IT MAY CONCERN:

directly in connection with its low-cost mass housing project, Cordova Tower -- Brgy. Sto. Nino, purposes located at Barangay Sto. Nifio, Marikina City, a project duly registered with the Board of beginning from May 2010 or actual start of commercial operation/selling, whichever is earlier, but Order No. 226, otherwise. known as the "Omnibus Investments Code of 1987" and Section Marikina City, consisting of 522 residential units used solely for family home or dwelling in no case earlier that the date of registration of the project with the BOI, pursuant to Executive 2.57.5(B)(2) of Revenue Regulations 2-98, as amended. Investments (BOI) under Registration No. This certifies that FEDERAL LAND, INC., with Tax Identification Number (TIN) , is exempt from income tax and creditable withholding tax on its income received dated August 15, 2008, for a period of 4 years

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 dwellings' with selling price of not more than Two Million Pesos (P2,000,000.00). January 1, 2021, the VAT exemption shall only apply to sale of house and lot and other residential Moreover, the sale by the Company of residential lots valued at P1,919,500.00 and below.

as the 13 commercial units and 174 parking slots, shall be subject to payment of appropriate taxes under the National Internal Revenue Code of 1997, as amended. the BOI, if any (per HLURB License to Sell No. The sale, however, of housing units in excess of the 522 residential units registered with , the excess is 13 residential units) as well

Company is liable, however, for all other applicable taxes not discussed above. applicable BIR rules and regulations and the Terms and Conditions stated at the back hereof. The The grant of tax exemption herein is subject to the compliance with the provisions of

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 documents

Issued this __day of_ JUL 1 6 2020

0u

CAESAR R.DULAY Commissioner of Internal Revenue

K - 1/spf18-2032 035856

Federal Land Inc.-Cordova Tower CTENo.-LEH383-202

Page 2 of 2 Date issued JUL 1 6 2020

TERMS AND CONDITIONS

OF THE CERTIFICATE OF TAX EXEMPTION

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

attributable to the revenues generated from the project, Cordova Tower --Brgy. Sto. Ninio

Marikina City, consisting of 522 residential units used solely for family home or dwelling

purposes located at Barangay Sto. Nino, Marikina City. Such exemption shall not cover

revenues from units with selling price exceeding P2,000,000.00.

2 The Company is obligated to construct and sell 522 residential units based on the following:

Condominium Unit Type (No. of Units) Product Mix (sq.m.) per unit) Floor Area

2-bedroom 1-bedroom 35 167 22.1 - 34.5 sq.m. 44.2 - 45 sq.m.

Total 522 15,371.7 sq.m.

and shall adhere to the following selling prices as represented:

Unit Type Unit Size in sq.m. Total No. of Units Price/Unit l-bedroom 22.1 341 I-bedroom 22.9 12 I-bedroom 34.5 2-bedroom 44.20 2 D 2-bedroom 45.00 38

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.

The Company's entitlement to ITH from its BOI-registered housing project is subject to the

compliance with the provisions of the Specific Terms and Conditions of its BOI Registration.

Pursuant to Section 4 of the Republic Act (RA) No. 107082, the Company is required to file

its tax returns and pay their 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 the periods prescribed under R.A. 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 at source as required under Chapter XIII and Section 57 of the Tax Code

of 1997, as amended and implemented by Revenue Regulations 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.

Finally, the Company's books of accounts and other pertinent records shall be subject to W

periodic examination by revenue enforcement officers of this Bureau for the purpose of

ascertaining whether it has been 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.

2 An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by