Foresight Realty & Development Corp.

October 28, 2020 CERTIFICATE OF TAX EXEMPTION NO. DT-620-20 CERTIFICATE OF TAX EXEMPTION issued to FORESIGHT REALTY & DEVELOPMENT CORPORATION 308 Concepcion Bldg., Sen. Gil Puyat Ave., Makati City, Philippines 1200 TIN: 000-000-000-000 This certifies that the donation under the Deed of Donation dated May 16, 2019, executed by the donor in favor of: Name of Donee TIN Address ROMAN CATHOLIC BISHOP OF ANTIPOLO, INC. Chancery Office, Mater Dei Formation Center, Antipolo City, Rizal 1870 covering the following property: Transfer Certificate of Title No. Area (sq.m.) Area Donated (sq.m.) Location 33,783 5,521 Sumulong Hi-way, Sta. Cruz, Antipolo City being a gift in favor of a religious corporation is exempt from the payment of the donor's tax pursuant to Section 101 (A) (2) 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. The donation is, however, subject to value-added tax (VAT) since the donor is a VAT-registered real estate developer and the donated properties are deemed ordinary assets, pursuant to Section 4.106-7 of Revenue Regulations No. 16-2005, the same being considered a transaction deemed sale. Moreover, transfers exempt from donor's tax under Section 101 (a) and (b) of Tax Code of 1997, as amended, shall be exempt from the tax imposed under Section 196 of the same Code. Accordingly, the Deed of Donation is likewise not subject to the documentary stamp tax prescribed under Section 196 of the Tax Code of 1997, as amended, but only to the documentary stamp tax of P30.00 imposed under Section 188 of the National Internal Revenue Code of 1997, as amended by R.A. No. 10963 or 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 28th day of October, 2020. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Renumbered by Republic Act No. 10963.