Front Nine Konstruct (Builders & Realty Development) Corporation/The One Dynamic Three Realty and Development Corporation Joint Venture (JV)

April 12, 2023 CERTIFICATE OF TAX EXEMPTION NO. NSH-029-2023 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that Front Nine Konstruct (Builders & Realty Development) Corporation/The One Dynamic Three Realty and Development Corporation Joint Venture (JV) , an entity engaged by the National Housing Authority (NHA), is exempt from project-related income taxes and creditable withholding tax (CWT) pursuant to Section 20 (d) (1) of Republic Act (RA) No. 7279, as amended by RA No. 10884 (Balanced Housing Development Program Amendments) dated July 17, 2016, on its income received directly in connection with the construction of Three Hundred Twenty-Eight (328) units of fully developed lots and completed housing units for Safari Ville, Brgy. Old Busuanga, Municipality of Busuanga, Palawan , a socialized housing project under the NHA's Yolanda Permanent Housing Project intended for those qualified beneficiaries affected by the calamity. ETHIDa Moreover, the delivery of the 328 socialized housing units shall be exempt from value-added tax (VAT) pursuant to Section 109 (1) (P) of the National Internal Revenue Code (Tax Code) of 1997, as amended, provided that the selling price thereof does not exceed P3,199,200.00 per house and lot package; provided further, that January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings 1 with selling price of not more than P3,199,200.00. 2 Furthermore, the Deeds of Absolute Sale executed by the Landowners in favor of Front Nine Konstruct (Builders & Realty Development) Corporation/The One Dynamic Three Realty and Development Corporation Joint Venture (JV) over the parcels of land described below, to wit: Date Name of Landowners Transfer Certificate of Title (TCT) Nos. Area (sq. m.) Transferred (sq. m.) Location Sept. 01, 2022 AAA married to BBB E-19729 25,727 11,377 Brgy. Old Busuanga, Municipality of Busuanga, Palawan, Sept. 01, 2022 AAA married to BBB E-19727 14,355 1,387 Brgy. Old Busuanga, Municipality of Busuanga, Palawan, Sept. 01, 2022 BBB married to AAA E-16165 12,117 2,840 Brgy. Old Busuanga, Municipality of Busuanga, Palawan, Sept. 01, 2022 CCC married to DDD E-36870 59,723 2,372 Brgy. Old Busuanga, Municipality of Busuanga, Palawan, Sept. 01, 2022 EEE married to FFF E-19766 15,148 4,838 Brgy. Old Busuanga, Municipality of Busuanga, Palawan, Total 127,070 22,814 which shall be used for the abovementioned socialized housing project are not subject to capital gains tax (CGT) pursuant to Section 20 (d) (2) of RA No. 7279, as amended, and to VAT pursuant to Section 109 (1) (P) of the Tax Code of 1997, as amended. TIADCc It is observed, however, that documentary stamp tax (DST) is not one of the taxes covered by the tax exemption clause in Section 20 of RA No. 7279. Thus, the documents conveying the properties shall be subject to DST imposed under Section 196 of the Tax Code of 1997, as amended, based on the consideration contracted to be paid for such realties or on their fair market value determined in accordance with Section 6 (E) of the same Code, whichever is higher. Likewise, lots/units classified as Economic Housing, not being covered by RA No. 7279, shall be subject to the payment of appropriate taxes. Moreover, the purchases of goods/articles by Front Nine Konstruct (Builders & Realty Development) Corporation/The One Dynamic Three Realty and Development Corporation Joint Venture (JV) shall be subject to VAT, even if the said purchases are to be used for the said socialized housing project, since VAT is an indirect tax which can be passed on by the seller of the goods/services. It shall be understood that Front Nine Konstruct (Builders & Realty Development) Corporation/The One Dynamic Three Realty and Development Corporation Joint Venture (JV) must issue VAT-exempt official receipts on its gross receipts from the said socialized housing project. 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 12th day of April, 2023. (SGD.) ROMEO D. LUMAGUI, JR. Commissioner of Internal Revenue Footnotes 1. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 2. As adjusted using the 2010 Consumer Price Index values pursuant to Revenue Regulations (RR) No. 8-2021 dated June 11, 2021.