BIR Ruling No. 210-12

March 23, 2012 BIR RULING NO. 210-12 RMC No. 18-2011 Chinatrust (Philippines) Commercial Bank Corporation 16th to 19th Floors, Fort Legend Towers 31st Street corner 3rd Avenue Bonifacio Global City Taguig City 1634 Attention: Lalaine Sta. Ana Trust Head Trust and Investments Services Division Gentlemen : This refers to your letter dated June 6, 2011 requesting for the confirmation of your opinion that any interest earned arising from the Chinatrust Long Term Trusteeship Account (CLTTA) and Chinatrust Long Term Investment Management Account (CLTIMA) will be exempt from the 20% final tax under Section 24 (B) (1) of the Tax Code of 1997, as amended, if the CLTTA and CLTIMA is kept with the Bank's Trust and Investment Services Division for a period of at least five (5) years and that the term of the underlying investment in which the Bank shall place the money of the Trustor shall likewise be for a period of at least 5 years. In reply, please be informed that with the issuance of Revenue Memorandum Circular (RMC) No. 18-2011 [Income Tax Exemption of Interest Income Earning from Long Term Deposits or Investment Certificates Under Sec. 24 (B) (1) and 25 (A) (2) of the National Internal Revenue Code of 1997, as amended] dated 12 April 2011, the issuance of a BIR ruling is not necessary as the taxability of the interest income from long-term deposits or investments is dependent on the full compliance of the requisites, otherwise, a final tax of twenty percent (20%) shall be imposed. Please be guided accordingly. cCTIaS Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue