Harmony Hills Subdivisions 1 and 2

March 7, 2018 CERTIFICATE OF TAX EXEMPTION NO. 329-18 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that NORTH LUZON RAILWAYS CORPORATION , with Tax Identification Number 000-000-000-000, is exempt from income tax, creditable withholding tax (CWT) and value-added tax (VAT) pursuant to Section 20 of Republic Act (RA) No. 7279 on its income received directly in connection with its sale of socialized housing units to qualified beneficiaries in Harmony Hills Subdivisions 1 and 2 , consisting of 151 housing units, 1 located at San Jose Del Monte City, Bulacan, a project duly certified by the Housing and Land Use Regulatory Board (HLURB) as a socialized housing in its Certification dated April 16, 2012. Nonetheless, it is observed that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Such being the case, the owner/project developer/seller shall be liable to pay the documentary stamp tax on the documents conveying the properties imposed under Section 196 of the Tax Code of 1997, as amended, based on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) of the same Code, whichever is higher. Moreover, the sale of the 151 socialized housing units is exempt from VAT provided that the selling price thereof does not exceed P1,919,500.00 for residential lot, and P3,199,200.00 for house and lot, pursuant to Section 109 (1) (P) of the 1997 Tax Code, 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 7th day of March, 2018. HTcADC (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. For distribution/sale to the 149 qualified beneficiaries listed in Annex "A" hereof.