Binding private Rulings - BPR 341-360

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 341 ​Distribution of a bank account as dividend in specie
BPR 342
​Donation by a resident to a foreign trust of property received from another foreign trust
BPR 343 ​Donations tax implications subscribing for shares at a discount
​​BPR 344 ​Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests
BPR 345 ​Asset-for-share transactions followed by an unbundling transaction and a sale of shares to a third party
​​BPR 346 ​Tax implications resulting from the elimination of intra-group loans
BPR 347 ​When the temporary setting aside of voluntary liquidation proceedings will not jeopardise roll-over relief
BPR 348 ​Income tax consequences for a public benefit organisation lending funds to qualifying entrepreneurs
BPR 349 ​Acquisition of equity shares in non-resident REIT
BPR 350 ​Vesting of a capital gain in a trust beneficiary and deferral of its payment
BPR 351 ​Waiver of an intra group loan to, and subsequent liquidation distribution by a subsidiary
BPR 352 ​Taxation of employees participating in an option programme
​​BPR 353 ​Linear adjustment of gross sales of unrefined mineral resource
BPR 354 ​Cash grants to an employee incentive trust and the transfer of share awards to qualifying employees

​BPR 355

​Accrual of pension payments to a resident from a foreign pension fund

BPR 356


​Preference share – hybrid equity instrument and third-party backed share
Last Updated: 25/11/2020 2:31 PM     print this page
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