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 400
Donations tax implications on the issue of shares at nominal value to enhance BBBEE credentials
BPR 399Asset-for-share transaction and replacement asset
BPR 398Disposal of shares pursuant to a property development arrangement
BPR 397Income tax and securities transfer tax consequences resulting from an amalgamation transaction
BPR 396Settlement of shareholder’s loans
BPR 395Termination of a venture capital company
BPR 394Instalment sale agreements and their sale to a non resident
BPR 393Income tax consequences resulting from consecutive asset-for-share transactions
BPR 392Sale of shares in a controlled foreign company (CFC)
BPR 391Tax consequences of the termination of an en commandite partnership
BPR 390Disposal in anticipation of liquidation
BPR 389Bursaries awarded by a resident company
BPR 388Application of the de-grouping rule following previous intra-group transactions under section 45
BPR 387Attribution of nett income to a public benefit organisation
BPR 386Share disposal between two employee share incentive trusts
BPR 385Use of preference share proceeds to fund employee share ownership plan
BPR 384Cession to special trust of the beneficiary’s loan account
BPR 383Transfer of profits for group tax purposes between controlled foreign companies
BPR 382Rebate in respect of foreign taxes
BPR 381Beneficial ownership in respect of back-to-back share transfers


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