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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 |
| 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 |
| 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 |
