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VIA EDGAR AND

VIA FACSIMILE

November 30, 2005

    Re:

    Accenture SCA

File No. 000-49713

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

Our letter dated July 1, 2005

Division of Corporate Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    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 October 24, 2005. To assist your review, we have
retyped the text of the Staff’s comments below.

Form 10-K

Note 1 Summary of Significant Accounting Policies

Revenue Recognition, page F-11

    1.

    Please explain to us in sufficient details the major terms of your outsourcing contracts,
including, but not limited to, the duration, billing and payment requirements, the rights of
cancellation and refund, and specific contractual performance milestones. Explain how you
considered these terms in your determination of how to recognize revenues. Disclose the
specific point in time that you recognize these revenues and tell us why you believe that the
earnings process is completed at that time. Disclose the accounting when you have further
obligations related to the services provided. As part of your response, please cite the
accounting literature that you are relying upon in your determination of how you account for
these arrangements.

    Response:

The Company has many different types of outsourcing contracts. The form and terms of contracts
vary depending on the type of work being outsourced, industry practices and specific client
negotiations. Our outsourcing contracts are typically long-term arrangements spanning anywhere
from 2 to 10 years. Billing requirements vary by client but generally include one or more of
the following types of billings: time-and-materials, cost-plus, fixed-price, unit-priced based
on transactions processed and/or incentive payments. Standard payment terms are 30 days. We
generally do not offer extended payment terms on outsourcing contracts. Incentive payments may
involve specific contractual performance milestones based on benefits delivered or other defined
metrics. For example, if cost savings from the outsourced operation of $x occurs, we could
receive a share of y%. Outsourcing contracts may be terminable by the client for convenience
with appropriate written notice. Such contracts may also be terminable for default by
either party.

    As disclosed in footnote 1 in our Form 10-K for the fiscal year ended August 31, 2004 , we
follow SAB 101, as amended by SAB 104, to account for our outsourcing arrangements. Revenues
are recognized on outsourcing contracts as amounts become billable in accordance with contract
terms, when billings correspond to services delivered and amounts are earned. Consistent with
the Staff’s guidance in Topic 13.A.1 of SAB 104, we consider amounts to be earned once evidence
of an arrangement has been obtained,

    services are delivered, fees are fixed or determinable, and
collectibility is reasonably assured. Revenue is deferred when billings do not correspond to
the services delivered (e.g., pre-billings), when we have further obligations related to the
services provided, or when client acceptance has not been received.

    We usually structure payment arrangements such that once amounts are paid they are not
refundable. In the event payments are refundable, we delay revenue recognition until the period
of availability of a refund passes. Revenue related to incentive payments is recorded when
delivery of the agreed-to benefits has occurred, any contingency is satisfied, and client
acceptance, where applicable, has been received.

    2.

    Tell us whether or not upon contract termination, the termination fee owed to you would be
the amount due to you if this had been a time and materials contract and how that affects
revenue recognition.

    Response:

Termination fees depend on the cause of termination and will differ based on the specific
contract terms and the facts and circumstances involved with each contract. That is, all
contracts do not specify that our termination payment is based on time and materials. When a
contract is terminated by a client for its convenience, our contracting standards require that
we are compensated for all work performed through the termination date based on the contractual
billing mechanism. Billings may take several different forms, as described in our response to
question 1 above. For example, on cost-plus contracts we typically would be paid on a cost-plus
basis for all costs incurred through the agreed termination date plus the specified margin
stated in the contract.

    Under any type of contract we are also generally entitled to compensation for demobilization
services required to transition the outsourced processes back to the client or another service
provider and termination charges to cover our foregone profits. Demobilization payments are
recorded as revenues over the period demobilization services are provided. Termination charges
are recorded as revenue upon the earlier of the date the termination agreement, if any, is signed
or when the payment is received, provided there are no remaining performance obligations
associated with the payments.

    We do not anticipate voluntary termination events to occur; therefore, termination does not
factor into our revenue recognition decision over the life of the contract. That is, we do not
rely on termination provisions to justify the amount of revenues recognized for our normal
service delivery.

    3.

    Tell us whether or not you incur significant start-up costs under these contracts and how
that affects revenue recognition.

    Response:

We define start-up costs as those related to substantive one-time efforts to establish a
business with an entirely new class of customers. We believe such costs are within the scope of
Statement of Position (SOP) 98-5 and we expense start-up costs as incurred as required by SOP
98-5.

    We define costs associated with establishing a new outsourced operation for an individual client
as “transition” or “set up activities”. Consistent with the Staff’s views in Question 3 of
Topic 13.A.3 (f) of SAB 104 we do not believe our transition costs are within the scope of SOP
98-5. Historically we have not experienced significant transition costs on our outsourcing
contracts, but the nature and complexity of our outsourcing business has evolved over time so
transition costs are becoming more significant. We believe our transition or set up activities
are consistent with the definition of costs eligible for capitalization in paragraphs 6(a) and
(b) of FASB Statement 91. Amounts billable to a client for transition or set-up activities are
deferred and recognized as revenue evenly over the period outsourcing services are provided
along with proportional amortization of related deferred costs, consistent with the guidance in
Topic 13.A.3 (f) of SAB 104.

    4.

    Please explain to us in sufficient details how you measure and recognize the costs relating to
each type of outsourcing contract and identify the elements of cost that you defer, if any.
Explain how you assess recoverability of these costs. Please cite the accounting literature that
you are relying upon in your determination of how you account for these costs.

    Response:

While deferred transition costs historically have not been material to our consolidated
financial statements, we have disclosed the paragraph below in our Form 10-K for the fiscal year
ended August 31, 2005 as we anticipate that these amounts will become more significant in the
future as our outsourcing business continues to grow. As noted in our response to question 3, we
believe our policy is in accordance with Topic 13.A.3 (f) in SAB 104, which refers to paragraphs
6 (a) and (b) in FASB Statement 91 as the basis for deferral of initial customer set-up costs
that are direct and incremental. The disclosure included in footnote 1 in our Form 10-K for the
fiscal year ended August 31, 2005 is as follows:

“Costs related to delivering outsourcing services are expensed as incurred with the
exception of certain transition costs related to the set-up of processes, personnel and
systems, which are deferred during the transition period and expensed evenly over the period
outsourcing services are provided. The deferred costs are specific internal costs or
incremental external costs directly related to transition or set-up activities necessary to
enable the outsourced services. Deferred amounts are protected in the event of early
termination of the contract and are monitored regularly for impairment. Impairment losses
are recorded when projected undiscounted operating cash flows of the related contract are
not sufficient to recover the carrying amount of contract assets. Deferred transition costs
were $71,102 and $50,196 at August 31, 2005 and 2004, respectively, and are classified in
current Unbilled services on the Consolidated Balance
Sheet. Amounts billable to the client for transition or set-up
activities are deferred and recognized as revenue evenly over the
period outsourcing services are provided.”

    5.

    Please refer to the last paragraph on page 48 relating to your client financing activities.
Explain to us what you mean by “...we contractually link payment for services to the achievement
for specified performance milestones” and how that affects revenue recognition. Also, explain
how you determine and account for the interest expense and interest income, if any, relating
to client financing.

    Response:

In limited circumstances, we agree to extend financing to clients on technology integration
consulting contracts. For these contracts, we recognize revenues using the
percentage-of-completion method pursuant to the AICPA Statement of Position 81-1, “Accounting
for Performance of Construction Type and Certain Production Type Contracts.” Estimated revenues
for applying the percentage-of-completion method only include estimated revenues from specified
performance milestones when the achievement of the defined goals is deemed probable.

    Payment terms associated with specified performance milestones result in delays in cash
collection but do not affect revenue recognition under the percentage of completion method of
accounting. That is, our work effort prior to receipt of specific client payments is funded
through working capital and is referred to as “client financing”. For contracts involving client
financing we impute interest income based on market rates. We conduct rigorous reviews
prior to signing contracts that involve client financing in order to evaluate whether payments
tied to specified performance milestones are reasonably achievable.

    We believe our accounting treatment for interest on client financing arrangements is in line
with paragraphs 12-14 of Accounting Principles Board Opinion 21 which stipulate that interest
should be imputed for arrangements using an approximation of the prevailing market rates. We
have clarified our disclosure on client financing, including the accounting for interest, in our Management Discussion & Analysis in our Form 10-K for the fiscal year ended August 31, 2005 as follows:

“In
limited circumstances, we agree to extend financing to clients on technology
integration consulting contracts. The terms vary by contract, but
generally we contractually link payment for services to the
achievement of specified performance milestones....
Imputed interest is recorded at market rates in interest income on
the Consolidated Income
Statement.”

A
similar disclosure was made in footnote 1 in our Form 10-K for the
fiscal year ended August 31, 2005.

Note 2 — Restructuring and Organization Costs (Benefits), page F-I 9

    6.

    We note your response to our comment no. 3 in your letter dated April 21, 2005 and your
response to our comment no. 1 in your letter dated July 1, 2005. With respect to the
information submitted, please provide the following:

    •

    We note that the Company identified certain shareholders who were partners at the time
of your reincorporation who may incur unusual or disproportionate financial damages in
certain jurisdictions and has recorded reorganization expense and related liability where
such liabilities are probable. Tell us how you determined for which partners you would
accrue a liability. Was your determination limited to certain tax jurisdictions or were
other criteria applied? Provide a breakdown of the liability by tax jurisdiction or other
criteria.

    •

    Tell us how you determined the probability of the tax payments when you recorded your
initial accrual in 2001, especially given the fact that the accrued liability has decreased
more from the expiration of the statute of limitations than from actual cash payments.

    •

    You indicate that in some countries these transactions were complex and the application
of local tax law was not clear. Given this statement, tell us how you were able to
reasonably estimate the amount of potential tax liability.

    •

    We note that you continue to accrue interest costs related to this charge. Is the
additional interest expense based on specific known tax liabilities or are you accruing
based on potential liabilities? If the former is the case, then tell us when you anticipate
paying the taxes or if the latter is the case, then tell us your basis for the additional
expense.

    •

    Tell us how you determine the amount of the accrued liability to be reversed in each
period.

    •

    Revise your disclosures to provide a more detailed discussion of the basis for the
reorganization liability. Provide a reconciliation of the liability for each period in
which an income statement is presented indicating the beginning balance, the benefit due to
the final determination, the additional interest expense accrued, cash payments and foreign
currency translation adjustments. Also, include a discussion of what constitutes a “final
determination” and when you anticipate this liability will be finally settled.

     Response:

    •

    We note that the Company identified certain shareholders who were partners at the time
of your reincorporation who may incur unusual or disproportionate financial damages in
certain jurisdictions and has recorded reorganization expense and related liability where
such liabilities are probable. Tell us how you determined for which partners you would
accrue a liability. Was your determination limited to certain tax jurisdictions or were
other criteria applied? Provide a breakdown of the liability by tax jurisdiction or other
criteria.

Prior to our transition to a corporate structure in fiscal 2001, we operated as a series of related
partnerships and corporations. In connection with our transition to a corporate structure, our
partners and shareholders (“partner” or
“partners”) exchanged all of their interests in
their partnerships and corporations for Accenture Ltd Class A common shares or, in the case of
partners resident in certain countries, Accenture SCA Class I common shares or Accenture Canada
Holdings Inc. (“ACHI”) exchangeable shares. Shortly after our transition to a corporate structure in fiscal
2001, Accenture Ltd (“Accenture”) successfully completed its initial public offering (“IPO”) for
its Class A common shares.

In order to proceed with this global reorganization to a corporate structure, Accenture’s senior
management sought the approval of its partners. In obtaining this approval, Accenture management
represented to the partners its intention to pursue reorganization transactions in which all
partners would be treated on a substantially equal basis and none would incur either immediate or
disproportionate individual in