E.M. Cuerpo, Inc.

January 24, 2018 CERTIFICATE OF TAX EXEMPTION NO. 035-18 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that E.M. CUERPO, INC. , (TIN: 000-000-000-000), is exempt from project-related income taxes, creditable withholding tax and value added tax (VAT), pursuant to Section 20 (d) (1) and (3) of Republic Act No. 7279, otherwise known as the "Urban Development and Housing Act of 1992," on its income received directly in connection with the construction/development of socialized housing units under the National Housing Authority (NHA)'s Yolanda Permanent Housing Program, to wit: Project Name Date of Contract Contract Price Date of Notice of Award Location No. of Socialized Housing Units subject of Tax Exemption St. Francis Village 2 February 20, 2017 P__________ May 23, 2016 Brgy. Suhi, Tacloban City 505 However, the purchases of goods/articles by E.M. CUERPO, INC. shall be subject to VAT, even if the said purchases are to be used for the socialized housing project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that E.M. CUERPO, INC. must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project. Moreover, the Deed/s of Absolute Sale executed by the Landowners in favor of the NHA over the parcels of land described below, to wit: Date of Deed of Absolute Sale Name of Landowner/Seller Original/Transfer Certificate of Title (OCT/TCT) No. Area (sq.m.) Area Transferred (sq.m.) Location December 6, 2016 Heirs of AAA 1 T-404 20,110 20,110 Barrio of Cabalawan, Tacloban City December 6, 2016 Heirs of AAA 2 22649 24,740 24,740 Barrio of Cabalawan, Tacloban City which shall be used for the above-mentioned socialized housing project, are not subject to capital-gains tax/expanded withholding tax and documentary stamp tax pursuant to Sections 19 and 20 of Republic Act (RA) No. 7279. It is, however, understood that this Certificate of Tax Exemption (CTE) is never intended, and shall not be construed, as giving authority to the concerned Register of Deeds to effect transfer of the land titles in the name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR. This Certificate of Tax Exemption is being issued on the basis of the facts and 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. Issued this 24th day of January, 2018. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. BBB, CCC, Heirs of DDD (EEE and FFF), Heirs of GGG (HHH, III and JJJ), and Heirs of KKK (LLL, MMM and NNN). 2. Ibid.