E.M. Cuerpo, Inc.

July 7, 2021 CERTIFICATE OF TAX EXEMPTION NO. NSH-232-2021 CERTIFICATE OF TAX EXEMPTION TO ALL WHOM IT MAY CONCERN : This certifies that E.M. Cuerpo, Inc. , an entity engaged by the National Housing Authority (NHA) , 1 is exempt from project-related income taxes and creditable withholding tax 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/development of 540 socialized housing units of low-rise buildings (LRBs) in Ciudad Kaunlaran located in Brgy. Molino II, Bacoor, Cavite, intended for the qualified members of Ciudad Kaunlaran Homeowners Association, Inc. (CKHOAI) for resettlement housing assistance under the National Resettlement Program of the government through the Community-Based Initiative Approach (CBIA). Moreover, the delivery of 540 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 beginning January 01, 2021, the exemption from VAT shall only apply to sale of house and lot and other residential dwellings 2 with selling price of not more than P2,000,000.00, as adjusted in 2011 using the 2010 Consumer Price Index values. 3 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 executed by the Landowner in favor of the NHA over the parcel of land described below, to wit: Date of Deed of Absolute Sale Name of Landowner/Seller 4 Transfer Certificate of Title Nos. Area (Sq.m.) Area Transferred (Sq.m.) Location May 27, 2021 Bacoor Seafront Development Corporation 52,718 14,471 Brgy. Molino II, Bacoor, Cavite which shall be used for the above-mentioned socialized housing project, is not subject to capital gains tax and documentary stamp tax pursuant to Sections 19 and 20 of RA No. 7279, and to VAT pursuant to Section 109 (1) (P) of the Tax Code of 1997, as amended. It is, however, understood that this Certificate of Tax Exemption (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, together with the documentary requirements provided under Revenue Memorandum Order (RMO) No. 15-2003, shall be presented to the Revenue District Office (RDO) concerned in order for the latter to issue the CAR. Upon application for exemption, a lien on the title of the land shall be annotated by the Register of Deeds having jurisdiction over the properties, to the effect that the same are to be applied or are being applied to a socialized housing project pursuant to RA No. 7279. DETACa This CTE 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 7th day of July, 2021. (SGD.) CAESAR R. DULAY Commissioner of Internal Revenue Footnotes 1. Per Memorandum of Agreement executed by and among E.M. Cuerpo, Ciudad Kaunlaran Homeowners Association and NHA dated October 13, 2020. 2. Sale of lot only, regardless of the price, shall be subject to VAT starting January 01, 2021 pursuant to RA No. 10963. 3. Per Revenue Regulations No. 4-2021 dated April 8, 2021. 4. Board Resolution was executed in favor of E.M. Cuerpo, Inc. to execute the Deed of Absolute Sale and all transactions with the NHA for housing project relating to the property on behalf of the landowner identified and described in TCT No. _________.