BIR Ruling [DA-461-04]

August 30, 2004 BIR RULING [DA-461-04] Science Savings and Loan Association, Inc. ITDI, DOST CPD., Gen. Santos Avenue, Bicutan Taguig, MM. Attention: Ms. Mercedes R. Soriano President, SSLAI Gentlemen : This refers to your letter dated July 26, 2004, requesting for a confirmation that the rulings issued by this Office has the effect of a certification and should be honored by your depository banks. It is represented that this Office issued DA-236-2004 dated May 7, 2004 exempting the Science Savings and Loan Association, Inc. (SSLAI) from the 20% final withholding tax on its interest income; and that when you presented the ruling to your depository banks, it was not honored and that you were informed that they needed a BIR certification specifically stating that SSLAI is tax exempt under Section 5 of Republic Act No. 8367 entitled "An Act Providing for the Regulation of the Organization and Operation of Non-Stock Savings and Loan Associations". In reply, please be informed that it is settled that the administrative interpretation of agencies charged with the enforcement of the law deserve respect and should be accorded great weight. STcAIa Accordingly, this Office reiterates the correctness of the issued ruling of the Law Division dated May 7, 2004 which was duly approved by the Deputy Commissioner of the Legal and Inspection Group and that there is no need for the issuance of a certification to that effect. Very truly yours, Commissioner of Internal Revenue By: (SGD.) MILAGROS V. REGALADO Assistant Commissioner Legal Service