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
Deductibility of the cost of assets to be acquired to construct roads
BPR 222 Foreign partnership – Rebate in respect of foreign taxes on income
BPR 223 Headquarter companies: Acquisitions of shares and loans
BPR 224 Non-resident – Source of income from the operation of ships
BPR 225 Hybrid debt instruments
BPR 226 Transfer of the long-term insurance business, partly to a third party and partly intra-group
BPR 227 Share subscription transaction followed by two share repurchase transactions
BPR 228 Whether an investment of preference share funding in a newly established business is for a “qualifying purpose”
BPR 229 Employer provided accommodation to employees
BPR 230 Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an intra-group transaction
BPR 231

Corporate restructuring by way of asset-for-share and amalgamation transactions

The principle confirmed in this ruling in respect of transaction 1 and 2 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 232 Equity shares to be issued by resultant company as part of an amalgamation transaction
BPR 233 Transfer of a part of a business to a fellow subsidiary
BPR 234 Asset-for-share and unbundling transactions not regulated by sections 42 and 46
BPR 235 Income tax consequences for parties to an unbundling transaction
BPR 236

Set-off of a loan account arising from an intra-group transaction to acquire equity shares

BPR 236 was replaced on 25 July 2016. The reference to African Holdco has been corrected to Foreign Holdco in subparagraph a)iii) in paragraph 6
BPR 237 Reinstatement of a deregistered company to transfer immovable properties
BPR 238 Taxation of receipts by or accruals to a programme of activities of a clean development mechanism project
BPR 239 Cash contributions made to a special purpose vehicle established to provide housing to mine workers
BPR 240 Taxation of parties to share index linked notes

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