Citihomes Builder and Development, Inc.

August 30, 2019 CERTIFICATE OF TAX EXEMPTION NO. 470-19 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that the donation under the Deed of Donation dated March 14, 2014, made and executed pursuant to Section 31 of Presidential Decree (PD) No. 957, as amended by PD No. 1216, mandating the donation by the owner or developer of roads, alleys, sidewalks, and playgrounds to Local Government Units, by and between: SCaITA Name of Donor TIN Address CITIHOMES BUILDER AND DEVELOPMENT, INC. 000-000-000-000 23rd Floor, The World Center, 330 Sen. Gil Puyat Ave., Makati City 1209 in favor of: Name of Donee TIN Address CITY GOVERNMENT OF SAN JOSE DEL MONTE, BULACAN - City of San Jose Del Monte, Bulacan covering the following properties: Transfer Certificate of Title (TCT) No. Total Area (sq. m.) Area Donated (sq. m.) Location T-516072 (M) 1,294 1,294 Barrio of Sto. Cristo, City of San Jose Del Monte, Bulacan T-516073 (M) 466 466 T-516074 (M) 211 211 T-516075 (M) 148 148 T-516076 (M) 575 575 being a gift in favor of a political subdivision of the Government, is exempt from the payment of the donor's tax pursuant to Section 101 (A) (2) 1 of the National Internal Revenue Code of 1997, as amended. Moreover, Section 185 of Regulations No. 26, otherwise known as the Revised Documentary Stamp Tax Regulations, implementing Title VII of the Tax Code, provides that conveyances of realties not in connection with a sale, to trustees or other persons without consideration are not taxable. Accordingly, the Deed of Donation is likewise not subject to the documentary stamp tax (DST) prescribed under Section 196 of the National Internal Revenue Code of 1997, as amended, but only to the DST of P15.00 2 imposed under Section 188 of the same Code. However, the donation is subject to value-added tax (VAT) since the donor is a VAT-registered real estate developer and the donated properties are deemed ordinary assets. Thus, the transfer is considered as "transaction deemed sale" pursuant to Section 106 (B) (1) of the National Internal Revenue Code of 1997, as amended, as implemented by Section 4.106-7 of Revenue Regulations (RR) No. 16-2005, as amended. 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. aTHCSE Issued this 30th day of August, 2019. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Now Section 101 (A) (1) of the National Internal Revenue Code of 1997, as amended by Republic Act (RA) 10963. 2. Old rate was used since the Deed of Donation was executed prior to the effectivity of RA No. 10963.