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VIA EDGAR AND

VIA FACSIMILE

July 1, 2005

    Re:

    Accenture SCA

File No. 000-49713

Form 10-K for the year ended August 31, 2004

Form 10-Q for the quarter ended November 30, 2004

Division of Corporation Finance

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549-0303

    Attention:

    Kathleen A. Collins, Branch Chief

Jorge Bonilla, Staff Accountant

Dear Ms. Collins and Mr. Bonilla:

     On behalf of Accenture SCA (the “Company”), we are providing the following responses to the
comments set forth in your comment letter dated June 17, 2005. To assist your review, we have
retyped the text of the Staff’s comments below.

Form 10-K

Note 2 — Restructuring and Organization Costs (Benefits), page F-19

1. We note your response to our previous comment no. 3. With regards to the 2001 restructuring
liability, please provide the following:

    •

    Please provide a reconciliation of the accrued liability for reorganization
costs at the end of each fiscal year, beginning with the $544 million accrued in fiscal
2001 for indirect taxes and other costs imposed on transfers of assets to a corporate
structure, and ending with the $454 million accrual outstanding at August 31, 2004.

    •

    Has the Company paid out any amounts against these liabilities or has the
reductions to the liability account been mainly through benefits recognized in income
resulting from final determinations?

    •

    Tell us what the “final determinations” entail. What is involved in the
determining the final settlement amounts and why do you anticipate this taking seven years,
2008?

    •

    Tell us what you mean by “certain shareholder and partners expenses related to
transfer of certain entities to Accenture as part of the reorganization”. What type of
expenses are you referring to? How and when do you intend on paying these expenses?

The $544 million of expense recorded in fiscal 2001 represented $89 million for restructuring and
$455 million related to non-income tax liabilities, such as stamp taxes, as well as liabilities for
certain shareholders’ and partners’ expenses.

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A reconciliation of the accrued liability for reorganization costs at the end of each fiscal year
through August 31, 2004 is set forth below:

    August 31,

    August 31,

    August 31,

    August 31,

    2001

    2002

    2003

    2004

    Reorganization liability balance, beginning of period

    $
    —

    $
    447

    $
    443

    $
    510

    Net (benefit) expense recorded

    544

    —

    (18
    )

    (78
    )

    Payments

    (97
    )

    (4
    )

    —

    —

    Foreign currency translation

    —

    —

    85

    22

    Reorganization liability, end of period

    $
    447

    $
    443

    $
    510

    $
    454

The reductions to the liability account have occurred due to $101 million of cash payments and $96
million through benefits recognized in income resulting from final
determinations through August 31, 2004. Additionally, net benefits totaling $29 million have been recognized in income from final
determinations in the six months ended February 28, 2005.

With respect to these
liabilities, a “final determination”
involves either the expiration of an applicable statute of limitations or a final agreement with a
tax authority. We anticipate that reorganization liabilities will be substantially diminished by
the end of fiscal year 2008 because final statutes of limitations will expire in a number of tax
jurisdictions by that year. However, tax audits or litigation may delay final settlements. A
final determination will either result in a payment on a final
settlement or the recording of a
reorganization benefit in our income statement. This approach to final determinations of our
reorganization liabilities is consistent with our approach involving tax matters and neither
approach adjusts for the risk of audit.

Shareholder and partner expenses primarily represent unusual and disproportionate individual
income tax exposures in certain tax jurisdictions that may be
applicable to certain, but not all, of our
shareholders who were partners at the time of our incorporation.
These exposures specifically related to the transfer of their partnership interests in certain
entities to Accenture as part of the reorganization. As most recently reiterated in our Annual
Report on Form 10-K for the fiscal year ended August 31, 2004, we have informed our partners that
the Company will, in certain circumstances, provide a legal defense to that partner if his or her
tax reporting position on the transfer of his or her interest into our corporate structure is challenged
by the relevant tax authority. In the event such a defense is unsuccessful, and the partner is then
subject to extraordinary financial disadvantage, we will review such circumstances for any
individual partner and find an appropriate way to avoid severe financial damage to that individual
partner. The Company has identified certain shareholders who were
partners at the time of our incorporation who may incur such unusual
and disproportionate financial damage in certain jurisdictions and has recorded reorganization
expense and the related liability where such liabilities are probable. If additional taxes are
assessed on our shareholders and/or partners in connection with these
transfers, we intend to make
payments to reimburse the costs associated with the assessment either
to the shareholder and/or
partner, or to the taxing authority.

********************************

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     Please do not hesitate to call Laurent C. Lutz at 312-693-7031 or Douglas G. Scrivner at
650-213-2136 with any questions or further comments you may have regarding this filing or if you
wish to discuss the above responses.

    Very truly yours,

Accenture SCA, represented by its

general partner, Accenture Ltd, itself

represented by its

duly authorized signatory

    /s/ Douglas G. Scrivner

    By:
    Douglas G. Scrivner

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