Binding Private Rulings (BPR)

Binding Private Rulings (BPR)

A Binding Private Ruling (BPR) is issued in response to an application and states how the Commissioner would interpret and
apply the provisions of the tax laws in relation to a specific proposed transaction.

• Income Tax Act, 1962 – Chapter III, Part IA
• Value-Added Tax Act, 1991 - section 41A (read with section 76O of the Income Tax Act, 1962)

The BPR Register provides a complete list of the Binding Private Rulings and can be used to locate the specific ruling's number.

To access the actual rulings, please use the links provided below:

• BPR 21 – 40
• BPR 41 – 60
• BPR 61 – 80
• BPR 81 – 100

Any comments on any of these rulings can be submitted to atrinfo@sars.gov.za.
Please indicate the following in the subject line: Comments on BPR ….. (Add the number of the specific ruling).

Binding General Rulings (BGR)
Binding Class Rulings (BCR)

Latest Additions to BPR's:  BPR 089 was added on 12 July 2010 

BPR  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
BPR 006		The application of section 24C in the context of a repair and maintenance contract
BPR 007		Service fees received by a non-resident labour broker
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
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 Acquisition of fixed property – exemption from transfer duty
BPR 016		Loans from a subsidiary company to a holding company
BPR 017		The supply of trophy, accommodation and services to a person who is not a resident of the Republic
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 rights by the beneficiary for Capital Gains Tax (CGT) purposes
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

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