Accenture Savings and Loan Association, Inc.

August 18, 2009 BIR RULING [DA-(TSF-005) 462-09] Section 5, R.A. No. 8367; DA-(TSF-003) 082-08; DA-560-07 Accenture Savings and Loan Association, Inc. 6767 G/Floor Makati Stock Exchange Building Ayala Avenue, Makati City 1200 Attention: Ybette Lim Treasurer Gentlemen : This refers to your letter June 1, 2009 requesting for a tax exemption certificate from income tax including interest on deposits with banks pursuant to Section 5 of Republic Act No. 8367 otherwise known as the Revised Non-Stock Savings and Loan Association Act of 1997. It is represented that Accenture Savings and Loan Association, Inc. ("ACCENTURE" for brevity), formerly ACI Savings and Loan Association, is a non-stock, non-profit organization duly registered with the Securities and Exchange Commission under SEC Registration No. ANO9202680 with Tax Identification No. 001-859-399 and that in support of your request, you submitted your Amended Articles of Incorporation, Amended By-Laws, and latest financial statements. In reply, please be informed that Section 5 of Republic Act (R.A.) No. 8367 provides that: CTacSE "Sec. 5. Tax Exemption. An association shall be exempt from payment of tax in respect to income it receives, including interest on its deposits with any bank: Provided, however, that income derived from any of its properties real or personal, or any activity conducted for profit, regardless of the disposition thereof, is subject to the corresponding internal revenue taxes imposed under the National Internal Revenue Code. Interest earnings on deposits of members with Associations, as well as the shares of its members from the net income of the Associations shall be exempt from income tax." HEIcDT From the foregoing, this Office holds that pursuant to the above provision of law, the interest income derived by ACCENTURE from its bank deposit and yield or any other monetary benefit from deposit substitutes shall be exempt from the 20% final withholding tax imposed under Section 27 (D) (1) of the Tax Code of 1997, as amended by R.A. 9337. (BIR Ruling No. 138-97 dated December 29, 1997) This ruling is being issued on the basis of the foregoing facts as represented. However, if upon investigation, it will be disclosed that the facts are different, then this ruling shall be considered null and void. Very truly yours, Commissioner of Internal Revenue By: (SGD.) JAMES H. ROLDAN Assistant Commissioner Legal Service