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RFN Construction & Development Corporation

Certificate of Tax Exemption No. 1147-18 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 31, 2018

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August 31, 2018 CERTIFICATE OF TAX EXEMPTION NO. 1147-18 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that RFN CONSTRUCTION & DEVELOPMENT CORPORATION (TIN: 000-000-000-000), an entity engaged by the National Housing Authority (NHA), 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, on its income received directly in connection with the construction/development of socialized housing units under the NHA's Yolanda Permanent Housing Program, to wit: Date of Notice of Award Date of Contract Agreement Contract Price (Php) Project Name Location No. of Socialized Housing Units subject to tax exemption September 19, 2017 December 4, 2017 P____________ St. Andrew Park Place 1 Site 1, Brgy. Daga Cadiz City, Negros Occidental 700 However, the purchases of goods/articles by RFN CONSTRUCTION & DEVELOPMENT CORPORATION 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 RFN CONSTRUCTION & DEVELOPMENT CORPORATION must issue VAT-Exempt official receipts on its gross receipts from the said socialized housing project. Moreover, the Deed of Absolute Sale/Unilateral Sale Executed by the Landowners in favor of the NHA over the parcel of land described below, to wit: Date of Deed of Absolute Sale Name of Landowners/Sellers 1 Transfer Certificate of Title No. Area (Sq. m.) Area Transferred (Sq. m.) Location December 1, 2017 AAA BBB CCC DDD T-23739 184,068 52,967 Brgy. Daga, Cadiz City, Negros Occidental which shall be used for the above-mentioned socialized housing project, is not subject to capital gains tax and documentary stamp tax under Sections 19 and 20 of Republic Act (RA) No. 7279. It is, however, understood that this CTE is never intended, and shall not be construed, as giving authority to the concerned Register of Deeds to effect transfer of 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. CAIHTE 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 31st day of August, 2018. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Special Power of Attorney dated March 23, 2016, was granted to AAA to execute the Deed of Absolute Sale on behalf of the landowners.

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