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 200​Source of income of commission payable to non-resident junket agents
BPR 199​Exemption from income tax of dividends received by virtue of restricted equity instruments
​BPR 198​Distribution of a debit loan account in anticipation of deregistration of a company
​BPR 197​Exemption from donations tax and net value of an estate
BPR 196Employees’ Tax: Monthly pension benefits in respect of foreign services rendered​

The guidance contained in this ruling is affected by subsequent law changes.
​BPR 195​Securities transfer tax exemption where election has been made that section 42 will not apply
BPR 194​Disposal of shares through a share buy-back and a donation
BPR 193​Debt reduction by way of set-off
​BPR 192​Cross border interest-free loan and withholding tax on interest
​BPR 191​Refinancing of debt through preference share funding
​BPR 190​Notional Funding Arrangement: The issue and potential repurchase of ordinary shares
BPR 189​Acquisition of shares subject to suspensive conditions
​BPR 188​Conversion of a public benefit organisation to a for-profit company
BPR 187​Waiver of an intra-group loan that funded the acquisition of a mining operation
BPR 186​Asset-for-Share transaction between a resident private company and a collective investment scheme (CIS) in securities
BPR 185​Corporate Rules: Disposal of assets and liabilities as part of a group restructure
BPR 184​Asset-for-Share Transaction
BPR 183​Employee Housing Scheme
​BPR 182​Waiver of debt that funded mining capital expenditure
BPR 181Withholding tax on interest re foreign government


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