Pioneer Ventures, Inc.

August 18, 2020 CERTIFICATE OF TAX EXEMPTION NO. DT-459-20 CERTIFICATE OF TAX EXEMPTION issued to PIONEER VENTURES, INC. Ciudades, Mandug, Davao City 8000 TIN: _________________ This certifies that the donation under the Deed of Donation dated March 01, 2018, executed by PIONEER VENTURES, INC. in favor of: Name of Donee TIN Address PHILIPPINE ARMY Headquarters 10th Infantry Division, CGMTY Sr., Brgy. Tuboran, Mawab, Compostela Valley covering the following property: Transfer Certificate of Title No. Area (sq.m.) Area Donated (sq.m.) Location 19,700 19,700 Buhangin, Manuel M. Garcia Road being a gift in favor of an agency of the National Government institution is exempt from the payment of the donor's tax pursuant to Section 101 (A) (1) 1 of the Tax Code of 1997, as amended, subject to the condition that not more than thirty percent (30%) of said gift shall be used by the donee for administration purposes. Moreover, Section 196 of the Tax Code of 1997, as amended, provides that transfers exempt from donor's tax under Section 101 (a) and (b) of the same Code shall be exempt from the documentary stamp tax imposed under said Section. Accordingly, the Deed of Donation is not subject to the documentary stamp tax prescribed under Section 196 of the 1997 Tax Code, as amended, but only to the documentary stamp tax of P30.00 imposed under Section 188 of the same Code, as amended by Republic Act No. 10963 or the TRAIN Law. 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 August, 2020. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Renumbered by Republic Act No. 10963.