Binding private Rulings - BPR 1-20 

A Binding Private Ruling (BPR) 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.
 
To access the rest of the BPRs, kindly use the navigation pane above.
 
 
 
​Number ​Subject
BPR 001 ​Definition of enterprise, zero-rating of salvage services, input tax deduction in respect of personal subsistence of employees
​BPR 002 ​Method for determination of the interest amount that accrues on the collection of a distressed debtors book
BPR 003 ​Method for determination of the valuation date value of financial instruments listed on a recognised exchange to be used for capital gains tax purposes
BPR 004 ​Definition of enterprise, exemption of goods on importation
BPR 005

​Whether dividend income received by a trust retains its nature in the hands of the beneficiaries on distribution thereof, by the trust, in the same tax year

The guidance contained in this ruling is affected by subsequent law changes 
​​BPR 006
​​The application of section 24C in the context of a repair and maintenance contract
 
Policy guidance on the subject provided in
Interpretation Note 78 "Allowance for future expenditure on contracts"
​​BPR 007
​Service fees received by a non-resident labour broker
 
The guidance contained in this ruling is affected by subsequent law changes
and policy guidance on the subject provided
in Interpretation Note 35 (issue 3) "Employees’ tax: Personal service providers and labour brokers"
BPR 008 ​Certain variable payments made to a marketing executive and the application of section 23(m)
BPR 009 ​Sale of an administration business
BPR 010 ​The applicability of the mining tax dispensations contained in the Act to a specific contract mining arrangement
​​BPR 011
​Transfer of a pre-1 March 1998 amount from a pension fund as an own contribution to other retirement funds
 
The guidance contained in this ruling is affected by subsequent law changes
BPR 012 ​Determination of gross income of a livestock auctioneer and agent
​BPR 013 ​Section 8C and the variation of share options obtained under a share option scheme
BPR 014 ​Employees' tax in respect of gains, as contemplated in sections 8A and 8C of the Act, made by retired employees
​​BPR 015 ​Supply of goods or services: Vendors one and the same person – section 8(25) of the VAT Act
Acquisition of fixed property: Exemption from transfer duty – section 9(1)(l) of the Transfer Duty Act
​​BPR 016
​Loans from a subsidiary company to a holding company
 
The guidance contained in this ruling is affected by subsequent law changes
BPR 017

​The supply of trophy, accommodation and services to a person who is not a resident of the Republic

Policy guidance on the subject provided in
Interpretation Note No. 81 "The supply of goods and services by professional hunters
and taxidermists to non-residents"
BPR 018 ​Deduction of letting commission paid by a property investment company to a property management company
BPR 019
Receipt of a cash payment  from a trust – disposal of vested rigths by the beneficiary for capital gains tax purposes​
 
The guidance contained in this ruling is affected by subsequent law changes and policy guidance on the subject provided in Comprehensive guide to capital gains tax (Issue 5)
​BPR 020
​Impact that the transfer of an amount of share premium of a company to another reserve of that company has on the nature of the share premium
 
The guidance contained in this ruling is affected by subsequent law changes
 
 
Last Updated: 10/04/2017 12:23 PM     print this page
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