Communities Panay, Inc.

February 22, 2019 CERTIFICATE OF TAX EXEMPTION NO. 172-19 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that COMMUNITIES PANAY, INC. , with Taxpayers Identification Number (TIN) 000-000-000-00000, is exempt from income tax and creditable withholding tax on its income received directly in connection with its economic and low-cost housing project (horizontal), Camella Aklan-Brgy. Joyao-Joyao, Numancia, Aklan consisting of 180 house and lot units located at Brgy. Joyao-Joyao, Numancia, Aklan, a project duly registered with the Board of Investments (BOI) under Registration No. 2017-192 dated June 28, 2017, for a period of 4 years beginning from June 2017 or actual start of commercial operations/selling, whichever is earlier, but in no case earlier than the date of 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 (RR) No. 2-98, as amended. HTcADC Moreover, the sale by the Company of residential lot valued at P1,919,500.00 and 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 National Internal Revenue Code of 1997, as amended. Provided, however, that beginning January 01, 2021, the VAT exemption shall only apply to sale of house and lot and other residential dwellings 1 with selling price of not more than P2,000,000.00. However, the sale of house and lot units in excess of the 180 house and lot units registered with the BOI (per HLURB License to Sell No. 031907, 2 the excess is 135 saleable lots w/units), shall be subject to the payment of appropriate taxes under the National Internal Revenue Code of 1997, 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. 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 22nd day of February, 2019. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue ATTACHMENT TERMS AND CONDITIONS OF THE CERTIFICATE OF TAX EXEMPTION 1. Camella Aklan-Brgy. Joyao-Joyao, Numancia, Aklan , consisting of 180 units located at Brgy. Joyao-Joyao, Numancia, Aklan. Such exemption shall not cover revenues from units with selling price exceeding P3,000,000.00. Moreover, the 315 units covered by License to Sell No. 031907 shall not be sold for more than P1,700,000.00 per house and lot. 2. 180 units based on the following schedules/sales revenues: Year Volume (No. of Units) Value (Php'000) 1 43 __________ 2 59 __________ 3 49 __________ 4 29 __________ Total 180 __________ 3. 4. 5. 3 the Company is required to file its tax returns and pay its tax liabilities, on or before the deadline as provided under the National Internal Revenue Code of 1997, 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 RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. 6.National Internal Revenue Code of 1997, as amended, and implemented by Revenue Regulations (RR) No. 2-98, as amended. 7. 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 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 National Internal Revenue Code of 1997, as amended. Footnotes 1. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 2. Per HLURB License to Sell No. 031907, 315 saleable lots with units are authorized for sale. 3. An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Promotion Agencies.