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

The guidance contained in this ruling is affected by new legislation. Refer to section 64EB.

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

Some guidance contained in this ruling is affected by subsequent law changes. Refer to section 42(8).

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

Legislative changes to section 20(1)(a), the repeal of paragraph 12(5) of the Eighth Schedule, and the enactment of section 19 and paragraph 12A of the Eighth Schedule should be noted.

BPR 123​Fibre optic cable to be used for electronic communications
BPR 122Transfer of a business of a company as a going concern to its holding company as a result of an amalgamation or merger transaction
BPR 121Secondary tax on companies or dividends tax

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