Binding Class Rulings - BCR 41-60

A Binding Class Ruling (BCR) is issued in response to an application and clarifies how the Commissioner would interpret and apply the provisions of the tax laws relating to a specific proposed transaction.
Applicable Legislation
  • Any tax Act administered by SARS as referred to in section 4 of the South African Revenue Service Act, 1997, excluding the Customs and Excise Act, 1964 
Number ​Subject
BCR 041 ​Dividends distributed by a foreign company
​​BCR 042 ​Preferred securities issued by a company registered in a foreign country
BCR 043 ​Antecedent cession of rights to future production rebate credit certificates (PRCCs)
BCR 044 ​Repurchase of non-redeemable, non-participating preference shares

BCR 044 has been replaced on 20 May 2014 to provide for textual changes and additions to the original ruling for improved clarity - refer to paragraph 5 and third bullet point in paragraph 7
BCR 045 ​Post retirement medical aid benefits  
BCR 046 ​Dividends distributed by foreign companies 
BCR 047 ​Limitation of dividend exemption 
​BCR 048 ​Deductibility of expenditure incurred by a portfolio of a collective investment scheme in securities
BCR 049​ ​Deductibility of insurance premiums in respect of an environmental maintenance programme guarantee
BCR 050 ​Tax consequences for unitholders in a REIT of an amalgamation transaction, followed by an asset-for-share transaction


The reference to Company B has been corrected to Company A in the third bullet point in paragraph 7.
BCR 051​ ​Taxation of employees participating in a perpetuity employee share incentive scheme
BCR 052
​Income tax and securities transfer tax consequences for the shareholders of a listed company following an unbundling transaction
BCR 053 ​Programme of activities of a clean development mechanism project
BCR 054 ​Employer-provided accommodation
BCR 055 ​Income tax and value-added tax consequences of a customer loyalty scheme
​Amalgamation of portfolios of declared hedge fund collective investment schemes with registered hedge fund collective investment schemes
BCR 057 ​Section 12J(2) deduction by partners
​​BCR 058 ​Consequences for beneficiaries on the unwinding of an employee share incentive scheme
​​​BCR 059 ​Asset for share transaction involving a foreign collective investment scheme
​​​​BCR 060 ​Consequences of an employee share trust disposing of the underlying shares and distributing the net proceeds to the beneficiaries


Last Updated: 16/03/2018 2:54 PM     print this page
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