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 120 | The interaction between sections 45 and 24J in the transfer of interest-bearing receivables under the corporate rules |
| BPR 119 | Transfer of amounts contributed to a foreign pension fund to a South African retirement annuity fund Some guidance contained in this ruling is affected by subsequent law changes. Refer to sections (9)(2)(i), 11F and paragraphs 2(1)(a) and 5(1)(a) of the Second Schedule. |
| BPR 118 | Withholding dividends tax |
| BPR 117 | Obligation to deduct or withhold employee’s tax in respect of a share option |
| 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 Some guidance contained in this ruling is affected by subsequent law changes. Refer to sections 10(1)(k)(ii) and 10B(2). |
| BPR 115 | Incentive rewards paid to independent sales persons |
| BPR 114 | Loan facilities raised by a foreign permanent establishment from which deposits and advances are made |
| BPR 113 | Expenditure associated with broad based black economic empowerment |
| BPR 112 | Interposing a co-operative between a South African holding company and its foreign subsidiaries |
| BPR 111 | Research and development expenditure paid to a fellow group company which is not a resident of South Africa |
| BPR 110 | Toll manufacturing agreement and the attribution of the global sales of South African manufactured products to a foreign business establishment |
| BPR 109 | Loan granted with embedded option |
| BPR 108 | Issue of redeemable preference shares from reserves available for distribution |
| BPR 107 | Recoupment of lease premium and rental amounts previously allowed as deductions in respect of a leased property |
| BPR 106 | Application of section 24C to a maintenance trust |
| BPR 105 | Tax implications for a resident relating to a single premium whole life insurance policy issued by an offshore insurer |
| BPR 104 | Intra-group transfer of shares as a result of restructuring |
| BPR 103 | Share incentive scheme |
| BPR 102 | Registration of an external company and identifying a permanent establishment |
| BPR 101 | Securities transfer tax – Asset-for-share transaction |
