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 260​Interest on loans used to acquire shares
​Capital gains tax implications for an employee share trust
​Corporate group restructuring
BPR 257

​Islamic financing arrangement

Replaced on 20 January 2017 to provide for textual changes and additions to the original ruling. For clarity, refer to paragraph 4, third bullet under proposed steps and first bullet under salient features. The sukuk certificate holders are referred to as a class. A separate Binding Class Ruling will therefore not be published.

​Mining rehabilitation
BPR 255​​Debt reduction by means of set-off
BPR 254​Consequences of cross-border and domestic asset-for-share transactions
​​​​​​​​​BPR 253​Donations tax consequences of a transaction to introduce a BEE shareholder into a group
​​​​​​​​BPR 252​Donations tax and capital gains tax consequences of the part waiver of a loan and reduction of the interest rate
​​​​​​​BPR 251​Cancellation of reinsurance agreement
​​​​​​BPR 250​Risk policies
​​​​​BPR 249​Corporate group restructuring involving multiple transactions
​​​​​BPR 248​Deduction of interest on asset backed notes
​​​BPR 247​Employer contributions to foreign social and pension funds in respect of a non-resident
​​BPR 246​Debt reduction and capitalisation
BPR 245​Time of accrual of short-term insurance premiums and time of supply of security provided to the Master of the High Court
BPR 244​Disposal of an undivided interest in immovable property by way of an amalgamation transaction
BPR 243​Termination of a subcontracting agreement and implementing of a toll manufacturing arrangement
BPR 242​Venture capital company investment in qualifying companies carrying on business as hotel keepers
​Award received for a black economic empowerment (BEE) training initiative


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