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 360Internal restructure followed by a disposal of shares to a BBBEE investor
​​​BPR 359Transfer of reinsurance business from a resident company to a local branch of a foreign company
BPR 358Amalgamation of short and long-term insurers
BPR 357Donations to a foreign trust of property situated outside the Republic
BPR 356Preference share – hybrid equity instrument and third-party backed share
BPR 355Accrual of pension payments to a resident from a foreign pension fund
BPR 354

Cash grants to an employee incentive trust and the transfer of share awards to qualifying employees

The principle confirmed in this ruling relating to paragraph 64E has been reviewed. This ruling should not be relied upon by anyone other than the Applicant(s)/class members to whom it was issued.

BPR 353Linear adjustment of gross sales of unrefined mineral resource
BPR 352​Taxation of employees participating in an option programme
BPR 351Waiver of an intra group loan to, and subsequent liquidation distribution by a subsidiary
BPR 350Vesting of a capital gain in a trust beneficiary and deferral of its payment
BPR 349​Acquisition of equity shares in non-resident REIT
BPR 348Income tax consequences for a public benefit organisation lending funds to qualifying entrepreneurs
BPR 347When the temporary setting aside of voluntary liquidation proceedings will not jeopardise roll-over relief
BPR 346Tax implications resulting from the elimination of intra-group loans
BPR 345Asset-for-share transactions followed by an unbundling transaction and a sale of shares to a third party
BPR 344Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests
BPR 343Donations tax implications subscribing for shares at a discount
BPR 342Donation by a resident to a foreign trust of property received from another foreign trust
​BPR 341​Distribution of a bank account as dividend in specie

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