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 220​​Contribution by a mining company to a trust pursuant to a share incentive scheme
BPR 219​​Corporatisation of a collective investment scheme in property and an amalgamation followed by an asset-for-share transaction

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 218​​Qualifying distributions to be made by a REIT ​
BPR 217​​Estate duty implications for non-resident individual investors
BPR 216​​Tax consequences of the issuing of additional tier 1 capital instruments by a registered bank
​BPR 215​Source and nature of satellite capacity fees
BPR 214​​Third-party backed shares
BPR 213​Repayment of intercompany loans from proceeds of a new share issue 
BPR 212​Tax consequences for the issuer and security company of listed credit linked notes
BPR 211​​Transfer of exchange items using corporate rules

The guidance contained in this ruling is affected by subsequent law changes.
​​BPR 210​Liquidation distribution followed by an amalgamation transaction
BPR 209​Dividends tax: Distribution of dividends to employees through a discretionary trust
​BPR 208​Repayment of shareholder’s loan from proceeds of a new share issue
​BPR 207​Merger of two controlled foreign companies (CFCs)
​BPR 206​Disposal by a share block company of its sectional title units to its share block holders
BPR 205​Meaning of “controlled group company” and “equity share”

BPR 204

Definition of “disposal” for purposes of asset-for-share and amalgamation transactions; “qualifying distribution” upon conversion to a corporate real estate investment trust (REIT)

BPR 203

​Renunciation of a usufruct over shares 

BPR 202

​Application of section 13quin subsequent to an intra-group transaction under section 45

BPR 201

Issue of capitalisation shares


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