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 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.
BPR 019
Receipt of a cash payment  from a trust – disposal of vested rights 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 018​Deduction of letting commission paid by a property investment company to a property management company
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 81 “The Supply of Goods and Services by Professional Hunters and Taxidermists to Non-residents”.
​​BPR 016
​Loans from a subsidiary company to a holding company
 
The guidance contained in this ruling is affected by subsequent law changes.
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
 
The guidance contained in this ruling is affected by subsequent law changes and policy guidance on the subject provided in Interpretation Note 57 “Sale of an Enterprise or part thereof as a Going Concern”.
BPR 014​Employees’ tax in respect of gains, as contemplated in sections 8A and 8C of the Act, made by retired employees
​BPR 013​Section 8C and the variation of share options obtained under a share option scheme
BPR 012​Determination of gross income of a livestock auctioneer and agent
​​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 010​The applicability of the mining tax dispensations contained in the Act to a specific contract mining arrangement
​​BPR 009
​Sale of an administration business
 
Policy guidance on the subject provided in Interpretation Note 57 “Sale of an Enterprise or part thereof as a Going Concern”.
BPR 008​Certain variable payments made to a marketing executive and the application of section 23(m)
​​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 “Employees’ Tax: Personal Service Providers and Labour Brokers (Issue 3)”.
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 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 004​Definition of enterprise, exemption of goods on importation
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

Some guidance contained in this ruling is affected by subsequent law changes. Refer paragraph 43(1A) which replaced paragraph 43(4).
​BPR 002​Method for determination of the interest amount that accrues on the collection of a distressed debtors book
BPR 001​Definition of enterprise, zero-rating of salvage services, input tax deduction in respect of personal subsistence of employees

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