Tax Exemption Granted to Cooperatives by the Cooperative Code Does Not Apply to Taxes on Income Not Arising from Cooperative Productive Activity

June 26, 1991 BIR RULING NO. 123-91 24 (e) (1) 000-00 123-91 Gentlemen : This refers to your letter dated March 21, 1991, requesting a Certificate of Exemption from the withholding tax on your interest income from bank deposits and raffle draw winnings from DBP Dagupan Branch, Kaluyagan Rural Bank and Homeowners Savings and Loan Association, Inc. of San Carlos City, on the ground that you are a credit cooperative duly registered under the provisions of R.A. No. 6938 otherwise known as the Cooperative Code of the Philippines. cdtech In reply, please be informed that your aforesaid request cannot be granted for lack of legal basis. The exemption granted to cooperatives by the Cooperative Code does not apply to taxes on income not arising from cooperative productive activity, such as interest on bank deposits, rentals, royalties, prizes and winnings. Very truly yours, (SGD.) JOSE U. ONG Commissioner