Philippine Investment Two (SPV-AMC), Inc.

May 8, 2018 CERTIFICATE OF TAX EXEMPTION NO. 780-18 CERTIFICATE OF TAX EXEMPTION issued to PHILIPPINE INVESTMENT TWO (SPV-AMC), INC. 1615 Ayala Tower One, Ayala Avenue cor. Paseo de Roxas, Makati City TIN: 233-834-04-000 This certifies that the Deed of Absolute Sale dated July 11, 2017, executed by PHILIPPINE INVESTMENT TWO (SPV-AMC), INC. in favor of: Name of Vendee TIN Address EL ELYON REALTY & DEVELOPMENT CORPORATION 406-248-626-000 Traveler's Life Bldg., J.R. Borja & Tiano Sts., Cagayan de Oro City covering the following properties: Transfer Certificate of Title Area (sq. m.) Area Transferred Location 137-2012000118 60,647 60,647 Lumbia, Cagayan de Oro City 137-2012000119 58,420 58,420 Lumbia, Cagayan de Oro City 137-2012000120 63,223 63,223 Lumbia, Cagayan de Oro City 137-2012000121 43,638 43,638 Lumbia, Cagayan de Oro City Total 225,928 intended for socialized housing project as certified by the Housing and Land Use Regulatory Board (HLURB), is not subject to capital gains/creditable withholding tax pursuant to Section 20 of Republic Act (RA) No. 7279. The transaction is, however, subject to documentary stamp tax under Section 196 of the Tax Code of 1997, as amended. Further, the intended socialized housing project shall be subject to pertinent issuances (clearances, Development Permit, Certificate and License to Sell) from HLURB and other government agencies concerned. It is, however, understood that this Certificate of Tax Exemption is never intended and shall not be construed as giving authority to the concerned Register of Deeds to effect transfer of the land title in the name of the buyer without the necessary certificate of authority to register issued by this Bureau. In this regard, this Certificate shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the Certificate Authorizing Registration (CAR). The CAR shall only be issued after the submission of the requirements provided under Revenue Memorandum Order (RMO) No. 15-2003. Furthermore, the Register of Deeds shall annotate on the titles of the lots to the effect that the said lots are to be utilized for socialized housing projects. This Certificate 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 8th day of May, 2018. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue