City & Land Developers, Inc.

October 18, 2019 CERTIFICATE OF TAX EXEMPTION NO. 660-19 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that the donation under the Deeds of Donation, both dated June 27, 2013, made and executed pursuant to Section 31 of Presidential Decree (PD) No. 957, as amended by PD No. 1216, by and between: HEITAD Name of Donor TIN Address CITY & LAND DEVELOPERS, INC. 000-000-000-000 2/F & 3/F Cityland Condominium 10, Tower 1, 156 H.V. Dela Costa St., Ayala North, Makati City 1226 in favor of: Name of Donee TIN Address CITY GOVERNMENT OF PARAAQUE 000-000-000-000 Paraaque City covering the following properties: Transfer Certificate of Title (TCT) Nos. Total Area (sq. m.) Area Donated (sq. m.) Location 68466 2,186.00 2,186.00 Brgy. Ibayo, Paraaque City 68467 392.00 392.00 68468 370.00 370.00 68469 1,056.00 1,056.00 68470 792.00 792.00 68471 530.00 530.00 68472 1,115.00 1,115.00 68473 1,961.00 1,961.00 68474 1,215.00 1,215.00 68475 680.00 680.00 68476 771.00 771.00 68477 662.00 662.00 68478 273.00 273.00 65843 81.00 81.00 65844 81.00 81.00 65850 81.00 81.00 65851 81.00 81.00 65854 81.00 81.00 65855 81.00 81.00 140851 246.88 246.88 140852 244.79 244.79 140854 80.59 80.59 108086 726.00 726.00 Brgy. La Huerta, Paraaque City 108174 475.00 475.00 108118 450.00 450.00 108175 276.50 276.50 108178 400.00 400.00 108179 1,474.50 1,474.50 108176 32.00 32.00 140669 82.00 82.00 being gifts 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 (NIRC) 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 Deeds of Donation are likewise not subject to the documentary stamp tax (DST) prescribed under Section 196 of the NIRC of 1997, as amended, but only to the DST of P15.00 2 imposed under Section 188 of the same Code. 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 18th day of October, 2019. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Now Section 101 (A) (1) of the NIRC of 1997, as amended by Republic Act (RA) No. 10963. 2. The old rate of P15.00 is used since the donations took place prior to the effectivity of RA No. 10963.