BPR 121-140

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 140	Unbundling transactions
BPR 139	Disposal of assets by a recreational club
BPR 138	Subscription for shares at nominal values coupled to a repurchase agreement at the same nominal values
BPR 137	Sale of a business in terms of an intra-group transaction
BPR 136	Taxation of subsistence allowances paid to employees
BPR 135	Improvements effected on land in terms of a long term lease
BPR 134	Exemption under section 10B(2)(a) in relation to a foreign dividend that is deemed to be received by a person who is a resident
BPR 133	Transfer of a residence out of a company to a natural person
BPR 132	Disposal of a business as a going concern by a trust to a company in exchange for shares in the company
BPR 131	Vesting date of a restricted equity instrument
BPR 130	Sale of mining rights and the respective base cost of each mining right
BPR 129	Beneficial owner of dividends
BPR 128	Disposal of equity shares in a foreign company
BPR 127	Relief from double taxation of foreign income
BPR 126	Disposal of a business and investment shares as a result of restructuring, and the distribution of certain shares to shareholders
BPR 125	Vesting by discretionary trust of dividend rights to the beneficiary of the trust
BPR 124	Repayment of shareholders’ loans from proceeds of a new issue of redeemable preference shares
BPR 123	Fibre optic cable to be used for electronic communications
BPR 122	Transfer of a business of a company as a going concern to its holding company as a result of an amalgamation or merger transaction
BPR 121	Secondary tax on companies or dividends tax

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