E.M. Cuerpo, Inc.

February 6, 2020 CERTIFICATE OF TAX EXEMPTION NO. NSH-147-2020 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that E.M. CUERPO, INC. (TIN: 000-000-000-000), an entity engaged by the National Housing Authority (NHA), is exempt from project-related income taxes, creditable withholding tax and value added tax (VAT), pursuant to Section 20 (d) (1) and (3) of Republic Act 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/development of socialized housing units under the NHA's Yolanda Permanent Housing Program, to wit: HTcADC Date of Notice of Award Date of Contract Agreement Contract Price (Php) Project Name Location No. of Socialized Housing Units subject of tax exemption June 15, 2017 Nov. 24, 2017 P___________ Gogo People's Village Site 2 Brgy. Gogo, Estancia Site 2, Iloilo 783 However, the purchases of goods/articles by E.M. CUERPO, INC. shall be subject to VAT, even if the said purchases are to be used for the 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 E.M. CUERPO, INC. must issue VAT-Exempt official receipts on its gross receipts from the said socialized housing project. Moreover, the Deed of Absolute Sale/Unilateral Sale Executed by the Landowners in favor of the NHA over the parcels of land described below, to wit: Date of Deed of Absolute Sale Name of Landowners/Sellers Original Certificate of Title No. Area (Sq. m.) Area Transferred (Sq. m.) Location July 22, 2019 AAA and BBB 1 F-46385 33,555 27,589 2 Brgy. Gogo, Estancia, Iloilo July 22, 2019 Spouses CCC and DDD 3 F-46381 23,322 22,898 4 Brgy. Gogo, Estancia, Iloilo July 22, 2019 EEE F-46588 31,682 18,609 5 Brgy. Gogo, Estancia, Iloilo July 22, 2019 EEE F-46588 31,682 1,732 6 Brgy. Gogo, Estancia, Iloilo which shall be used for the above-mentioned socialized housing project, is not subject to capital gains tax and documentary stamp tax under Sections 19 and 20 of Republic Act (RA) No. 7279. It is, however, understood that this CTE is never intended, and shall not be construed, as giving authority to the concerned Register of Deeds to effect transfer of the land titles in the name of the buyer without the necessary Certificate Authorizing Registration (CAR) issued by this Bureau. In this regard, this CTE shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR. 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 6th day of February, 2020. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Special Power of Attorney dated July 19, 2019, was granted to FFF to execute the Amended Deed of Absolute Sale on behalf of the landowners. 2. The original area of 30,649 sq.m. transferred per Deed of Absolute Sale dated March 27, 2018 was adjusted to 27,589 sq.m. per Amended Deed of Absolute Sale dated July 22, 2019 due to revision in the area covered for the development of the said project. 3. Special Power of Attorney dated July 19, 2019, was granted to FFF to execute the Amended Deed of Absolute Sale on behalf of the landowners. 4. The original area of 23,218 sq.m. transferred per Deed of Absolute Sale dated March 27, 2018 was adjusted to 22,898 sq.m. per Amended Deed of Absolute Sale dated July 22, 2019 due to revision in the area covered for the development of the said project. 5. An area of 18,609 sq.m. per Amended Deed of Absolute Sale dated July 22, 2019, was added due to revision in the area covered for the development of the said project. 6. An area of 1,732 sq.m. per Amended Deed of Absolute Sale dated July 22, 2019, was added due to revision in the area covered for the development of the said project.