BPR 41-60

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.

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Number	Subject
BPR 060	Short sale transactions and securities lending arrangements
BPR 059	Corporate rules – Transfer of the assets of a businesses conducted by a sole proprietor to companies and close corporations Some guidance contained in this ruling is affected by subsequent law changes. Refer to section 8(25) of the VAT Act.
BPR 058	Acquisition of shares as a result of company restructuring and interest on a loan created in the restructuring process
BPR 057	Interest incurred on a loan obtained to acquire the business of a company as a going concern through the acquisition of the shares of the company
BPR 056	Taxability of income and capital gains in the hands of vesting beneficiaries whether a resident or not (Income Tax Act, 1962)
BPR 055	Application of the definition of ‘dividend’ to the redemption of a participatory interest by a foreign collective investment scheme The guidance contained in this ruling is affected by new legislation.
BPR 054	Corporate rules – amalgamation transactions
BPR 053	Value-added tax implications arising from the construction of buildings by an entity and the subsequent donation of such buildings to another entity
BPR 052	Repatriation of profits in the form of foreign dividends paid by a foreign subsidiary to a resident company which was previously exempt from income tax The guidance contained in this ruling may be affected by subsequent law changes.
BPR 051	Environmental expenditure allowances
BPR 050	Cash grants made by an employer to share-incentive scheme trusts and their deductibility for tax purposes
BPR 049	Nature of proceeds received for the lease of property in terms of a 99 year lease The guidance contained in this ruling is affected by subsequent case law.
BPR 048	Deeming a place of business to be a ‘foreign business establishment’ as envisaged in section 9D(1) The guidance contained in this ruling is affected by subsequent law changes.
BPR 047	Agency income earned by a controlled foreign company to be excluded from its net income The guidance contained in this ruling is affected by subsequent law changes.
BPR 046	Accrual of an unclaimed retirement fund (lump sum) benefit
BPR 045	Deductibility of conditional interest incurred in terms of a loan
BPR 044	Foreign business establishment exclusion The guidance contained in this ruling is affected by subsequent law changes.
BPR 043	Private use of a company motor vehicle
BPR 042	Determination of who qualifies as a ‘film owner’ for purposes of section 24F The guidance contained in this ruling is affected by subsequent law changes.
BPR 041	Impact of the de-grouping provisions where the transferror in the first intra-group transaction and the transferee in the second intra-group transaction are the same company

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