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