Unicon Insurance Brokers Corporation

March 3, 2009 BIR RULING [DA-(TAR-002) 133-09] Sections 46 & 47; DA-404-2000, DA-345-05 Unicon Insurance Brokers Corporation 40/F Robinsons Equitable Tower, (JG Summit Holdings, Inc.) ADB Avenue cor. P. Poveda Road, Ortigas Center, Pasig City Attention: Mr. James L. Go Chairman Gentlemen : This refers to your letter dated August 5, 2008 requesting for authority to change the accounting period of Unicon Insurance Brokers Corporation (hereafter "UNICON") from fiscal year ending September 30 to calendar year ending December 31, effective January 1, 2009. SAaTHc It appears that UNICON with Taxpayer Identification No. 350-000-284-602 is a domestic corporation registered under Philippine laws with office address at E. Rodriguez Jr., Ave., Bagong Ilog, Pasig City; and that UNICON intends to change its accounting period from fiscal year basis (October 1-September 30) to calendar year basis (January 1 to December 31); that the purposes for the change are to align UNICON's accounting period with the parent company's calendar year accounting period and with the Insurance Commission's requirement to submit audited financial statements and supporting schedules, documents and reports on a calendar year basis; that the Board of Directors of UNICON unanimously approved the change in accounting period; and that since incorporation, UNICON's books accounts were opened on October 1 and closed on September 30 of the following year, as shown in the income tax returns and financial statements of the corporation. In reply, please be informed that your request is hereby granted, provided, you comply with the provisions of Section 46 and 47 of the Tax Code of 1997 which states: "SEC. 46. Change of Accounting Period. If a taxpayer, other than an individual, changes his accounting period from fiscal year to calendar year, from calendar year to fiscal year or from one fiscal year to another, the net income shall, with the approval of the Commissioner, be computed on the basis of such new accounting period, subject to the provisions of Section 47. SEC. 47. Final or Adjustment Returns for a Period of Less than Twelve (12) Months . (A) Returns for Short Period Resulting from Change of Accounting Period. If a taxpayer, other than an individual, with the approval of the Commissioner, changes the basis of computing net income from fiscal year to calendar year, a separate final or adjustment return shall be made for the period between the close of the last fiscal year for which return was made and the following December 31. If the change is from calendar year to fiscal year, a separate final or adjustment return shall be made for the period between the close of the last calendar year for which return was made and the date designated as the close of the fiscal year. If the change is from one fiscal year to another fiscal year, a separate final or adjustment return shall be made for the period between the close of the former fiscal year and the date designated as the close of the new fiscal year. EIAaDC (B) Income Computed on Basis of Short Period. Where a separate final or adjustment return is made under Subsection (A) on account of a change in the accounting period, and all other cases where a separate final or adjustment return is required or permitted by rules and regulations prescribed by the Secretary of Finance, upon recommendation of the Commissioner, to be made for a fractional part of a year, then the income shall be computed on the basis of the period for which separate final of adjustment return is made. In view of the foregoing, UNICON should file a separate final or adjustment return for the period corresponding to September 30 to December 31, 2008, which is the period between the close of the last fiscal year and the following December 31. This will serve as authority for UNICON to change its accounting period from fiscal year to calendar year upon compliance with the requirement of filing a short period return. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service