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 180

​Improvements effected on land not owned by taxpayer

BPR 179

​Single premium life insurance policy issued by an off-shore insurer

​BPR 178

​International corporate restructuring

BPR 177

​Improvements on land by sub-lessee under a sub-lease

BPR 176

​Financial instruments not issued by a “listed company” as defined; Application of the words “for investment purposes”

BPR 175

​Debt purchase transactions

BPR 174

Receipts of an incentive trust and vesting of shares in qualifying employees

Some of the guidance contained in this ruling is affected by subsequent law changes. Refer to BPR 354.

BPR 173

Repayment of shareholder loan from proceeds of a new issue of ordinary shares

BPR 172

Plant used in the production of renewable energy

BPR 171

​Amalgamation transaction

The principle confirmed in this ruling has been reviewed. This ruling should not be relied upon by anyone other than the Applicant(s) or class members to whom it was issued.

BPR 170

​Definition of unrestricted equity instrument

BPR 169

​Commercial building allowance
BPR 168

​Corporate rule: Disposal of assets within 18 months of acquisition

BPR 167

​Debentures tracking the value of a reference asset

BPR 166

​Change of place of incorporation (domicile) of a controlled foreign company

​BPR 165

​Letting of accommodation where the provision of meals is outsourced

BPR 164  

​Buyback of shares at a purchase price in excess of their market value

BPR 163 


​Interest on replacement loans and proceeds arising from a share repurchase

BPR 162

​Sale of an oil and gas right

BPR 161

Employee share ownership plan


Table of Contents

Last Updated: