BIR Ruling No. 364-2022

REPUBLIC OF THE PHi'LIPPINES

DEPARTMENT OF FINANCE BUREAU OF INTERNAL REVENUE

Sec. 5 RA No. 8367 BIR Ruling Nos. 519-2011 & 0438- 2020 0354-2022 AUG12_2022

Grescent Park West, Bonifacio Global City Savings and Loan Association of P & G Phils. Employees, (PECA), Inc. Taguig City, 1634 1oth Floor Net Park, 5th Avenue

Attention: Grace Salvador-Sison

President

Gentlemen:

percent (20%) final withholding tax on its interest income derived from deposits and deposit G Phils., Employees, (PECA), Inc. for revalidation of its certificate of exemption from the twenty took effect on November 14, 1997. substitutes pursuant to Republic Act (RA) No. 8367; approved on October 21, 1997 and which This refers to your letter requesting on behalf of the Savings and Loan Association of P &

Candon B. Guerrero, Director of the Supervision and' Examination Department III of the Bangko Sentral ng Pilipinas. the laws of the Philippines, with office address at .10/F Net Park, 5th Avenue, Crescent Park West, Bonifacio Global City, Taguig City, 1634; that it is registered with the Securities and Exchange Stock Savings and Loan Association per Certification dated February 24, 2003 issued by Mr. Commission (SEC) bearing SEC Certificate of Registration No. by the government and permitted by the Bangko Sentral ng Pilipinas (BSP) to operate as a Non- Documents submitted show that PECA is a non-stock corporation duly organized under ; and that it is recognized

Providing for the Regulation of the Organization and Operation of Non-Stock Savings and Loan Associations", provides, viz.: In reply, please be informed that Section 5 of Republic Act No. 8367, entitled: "An Act

to the corresponding internal revenue taxes imposed under the National Internal tax in respect to income it receives, including interest on its deposits with any bank: or any activity conducted for profit, regardless of the disposition thereof, is subject Revenue Code. Provided, however, that income derived from any of its properties, real or personal. "SEC. 5. Tax Exemption. -- An Association shall be exempt from payment of

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Interest earnings. on deposits of members: with Association, as well as the shares of its members from the net income of the Associations shall be exempt from income tax. "

Based on the foregoing, Savings and Loan Association of PECA shall be exempt from income tax, with respect to income it receives. Also, interest income derived by it from its deposit and deposit substitutes are exempt from twenty percent (20%) final withholding tax (BIR Ruling No. 519-2011 dated December 22, 2011)

However, 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.

upon investigation, it will be disclosed that the facts: are different, then this ruling shall be Considered null and void. This ruling is being issued on the basis of the foregoing facts as represented. However, if

Very truly yours.

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO hal l Gnll S 000468