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 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 373STT treatment of the proposed transfer of listed shares to the applicant in order to hedge its exposure under over-the-counter derivative transactions
BPR 372Withholding tax on foreign royalties
BPR 371Public benefit activities carried on for the benefit of the general public
BPR 370Registration of shares in the name of beneficial holder
BPR 369Deductibility of interest incurred pursuant to liquidation of company
BPR 368Payments made pursuant to an agreement relating to a permission to occupy
BPR 367Employment tax incentive
BPR 366Distribution in specie of shares
BPR 365Interpretation and application of the de-grouping provision in section 45(4)(b)
BPR 364Extraordinary dividend followed by the dilution of shareholders’ interest
BPR 363Value of a supply of services
BPR 362Transfer of assets between share incentive trusts
BPR 361Asset-for-share transaction followed by an unbundling transaction, the issue of capitalisation redeemable preference shares and the sale of shares to a third party

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