Binding private Rulings - BPR 101-120

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.
The rest of the BPRs may be accessed by navigating the pane above.
​Number ​Subject
BPR 101 Securities transfer tax - Asset-for-share transaction
BPR 102 Registration of an external company and identifying a permanent establishment
BPR 103 ​Share incentive scheme
BPR 104 ​Intra-group transfer of shares as a result of restructuring
BPR 105 ​Tax implications for a resident relating to a single premium whole life insurance polic issued by an offshore insurer
BPR 106 ​Application of section 24C to a maintenance trust
BPR 107 ​Recoupment of lease premium and rental amounts previously allowed as deductions in respect of a leased property
BPR 108 ​Issue of redeemable preference shares from reserves available for distribution
BPR 109 ​Loan granted with embedded option
BPR 110 ​Toll manufacturing agreement and the attribution of the global sales of South African manufactured products to a foreign business establishment
BPR 111 ​Research and development expenditure paid to a fellow group company which is not a resident of South Africa
​BPR 112 ​Interposing a co-operative between a South African holding company and its foreign subsidiaries
BPR 113 ​Expenditure associated with broad based black economic empowerment
BPR 114 ​Loan facilities raised by a foreign permanent establishment from which deposits and advances are made
BPR 115 
​Incentive rewards paid to independent sales persons
BPR 116 ​Distribution to be received by a resident beneficiary from a trust that is not a resident and the subsequent donation thereof by the beneficiary to another trust that is also not a resident
BPR 117 ​Obligation to deduct or withhold employee's tax in respect of a share option
BPR 118 ​Withholding dividends tax
BPR 119 ​Transfer of amounts contributed to a foreign pension fund to a South African retirement annuity fund
BPR 120 ​The interaction between sections 45 and 24J in the transfer of interest-bearing receivables under the corporate rules





Last Updated: 14/02/2019 4:08 PM     print this page
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