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.
BPR 160Incentive payments

Replaced on 24 January 2014 due to the amendment of point 6.
​BPR 159​Asset-for-share and amalgamation transactions
​​BPR 158
​Transport services provided by an employer to employees
The underlying principles confirmed in this ruling are currently under review. This ruling is only binding in respect of the specific applicant to whom it was issued and may not be relied upon by a third party.
BPR 157​Receipt of foreign assets and the subsequent donation thereof to a non-resident trust
BPR 156​Pension benefits accruing to a non-resident from a resident pension fund
​BPR 155Incentive for oil and gas production
BPR 154​Corporate rules: Acquisition of a debtors book
BPR 153Residency status of a non-resident who applies for a temporary residence permit
BPR 152Capital Gains Tax: Cancellation and extinguishment of a right to interest
BPR 151​Renunciation of an inheritance
BPR 150​Tax treatment relating to a credit linked deposit
BPR 149Disposal of an asset that constitutes an equity share in a foreign company

BPR 149 has been replaced on 14 August 2013 to provide for textual changes and additions from the original ruling for improved clarity – refer to the first bullet point in paragraph 6.
BPR 148​Dividends Tax Rate – Permanent establishment in South Africa
​​BPR 147​Consideration received for the surrender of a right to acquire shares
BPR 146​Mining tax – Contract mining agreement
BPR 145​Allowances  – Assets forming part of a sale and leaseback arrangement
BPR 144 ​Write-off period in respect of the increase in either the cost or the value of assets pursuant to a section 45(4) de-grouping
BPR 143 ​Preference shares constituting equity shares in relation to a headquarter company
BPR 142​Deduction of interest expenditure
BPR 141Transfer of securities from an untaxed policyholder fund of a long-term insurer to an untaxed policyholder fund of another long-term insurer


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