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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 380 | Transfer of shares in resident company to non-resident holding company |
| BPR 379 | Qualifying purpose |
| BPR 378 | Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests |
| BPR 377 | Withholding of dividends tax at a reduced rate |
| BPR 376 | Corporate restructuring |
| BPR 375 | Unbundling of shares in a CFC |
| BPR 374 | Determination of group of companies |
| BPR 373 | STT treatment of the proposed transfer of listed shares to the applicant in order to hedge its exposure under over-the-counter derivative transactions |
| BPR 372 | Withholding tax on foreign royalties |
| BPR 371 | Public benefit activities carried on for the benefit of the general public |
| BPR 370 | Registration of shares in the name of beneficial holder |
| BPR 369 | Deductibility of interest incurred pursuant to liquidation of company |
| BPR 368 | Payments made pursuant to an agreement relating to a permission to occupy |
| BPR 367 | Employment tax incentive |
| BPR 366 | Distribution in specie of shares |
| BPR 365 | Interpretation and application of the de-grouping provision in section 45(4)(b) |
| BPR 364 | Extraordinary dividend followed by the dilution of shareholders’ interest |
| BPR 363 | Value of a supply of services |
| BPR 362 | Transfer of assets between share incentive trusts |
| BPR 361 | Asset-for-share transaction followed by an unbundling transaction, the issue of capitalisation redeemable preference shares and the sale of shares to a third party |
