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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 |
|---|---|
| BPR 360 | Internal restructure followed by a disposal of shares to a BBBEE investor |
| BPR 359 | Transfer of reinsurance business from a resident company to a local branch of a foreign company |
| BPR 358 | Amalgamation of short and long-term insurers |
| BPR 357 | Donations to a foreign trust of property situated outside the Republic |
| BPR 356 | Preference share – hybrid equity instrument and third-party backed share |
| BPR 355 | Accrual 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 353 | Linear adjustment of gross sales of unrefined mineral resource |
| BPR 352 | Taxation of employees participating in an option programme |
| BPR 351 | Waiver of an intra group loan to, and subsequent liquidation distribution by a subsidiary |
| BPR 350 | Vesting of a capital gain in a trust beneficiary and deferral of its payment |
| BPR 349 | Acquisition of equity shares in non-resident REIT |
| BPR 348 | Income tax consequences for a public benefit organisation lending funds to qualifying entrepreneurs |
| BPR 347 | When the temporary setting aside of voluntary liquidation proceedings will not jeopardise roll-over relief |
| BPR 346 | Tax implications resulting from the elimination of intra-group loans |
| BPR 345 | Asset-for-share transactions followed by an unbundling transaction and a sale of shares to a third party |
| BPR 344 | Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests |
| BPR 343 | Donations tax implications subscribing for shares at a discount |
| BPR 342 | Donation 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 |
