Binding private Rulings - BPR 221-240

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
​Deductibility of the cost of assets to be acquired to construct roads
BPR 222 Foreign partnership – Rebate in respect of foreign taxes on income
BPR 223 ​Headquarter companies: Acquisitions of shares and loans
BPR 224 ​Non-resident – Source of income from the operation of ships 
​BPR 225 ​Hybrid debt instruments
BPR 226 ​Transfer of the long-term insurance business, partly to a third party and partly intra-group
BPR 227 ​Share subscription transaction followed by two share repurchase transactions

BPR 228

​Whether an investment of preference share funding in a newly established business is for a "qualifying purpose"
BPR 229​ ​Employer provided accommodation to employees
BPR 230​ ​Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an intra-group transaction
BPR 231 ​Corporate restructuring by way of asset-for-share and amalgamation transactions
​BPR 232​ ​Equity shares to be issued by resultant company as part of an amalgamation transaction
BPR 233 ​Transfer of a part of a business to a fellow subsidiary
BPR 234​ ​Asset-for-share and unbundling transactions not regulated by sections 42 and 46
BPR ​235 ​Income tax consequences for parties to an unbundling transaction
BPR 236

​Set-off of a loan account arising from an intra-group transaction to acquire equity shares

BPR 236 was replaced on 25 July 2016. The reference to African Holdco has been corrected to Foreign Holdco in subparagraph a)iii) in paragraph 6

BPR 237 ​Reinstatement of a deregistered company to transfer immovable properties
BPR 238 ​Taxation of receipts by or accruals to a programme of activities of a clean development mechanism project
BPR 239 ​Cash contributions made to a special purpose vehicle established to provide housing to mine workers
​BPR 240
​Taxation of parties to share index linked notes


Last Updated: 14/02/2019 3:59 PM     print this page
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