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 100​Date of accrual of short-term insurance premiums payable in terms of a guarantee policy, suretyship provided to the Master of the High Court and the time of supply of the guarantee policy
BPR 099​Transfer of beneficial ownership of South African listed shares under a ‘riskless principal’ transaction
BPR 098​Capital gain or loss on ceded policies
BPR 097​Capital gains tax liability in relation to assets of a trust which vest in the hands of the vesting beneficiaries
​BPR 096​Group restructuring transactions and possible relief measures
BPR 095​Adequate consideration as contemplated under section 58(1)
BPR 094​Charges incurred in relation to the acquisition of trading stock
BPR 093​Deductibility of environmental expenditure subsequently incurred in respect of asset that have been acquired in an asset-for-share transaction
BPR 092

​Possible recoupment of rental paid on the subsequent acquisition of the leased property by the lessee

The principle confirmed in this ruling has been reviewed. In addition, subsequent law changes occurred. This ruling should not be relied upon by anyone other than the Applicant(s)/class members to whom it was issued.

BPR 091​Securities lending transaction
BPR 090

​Royalty income attributable to a foreign business establishment of a controlled foreign company

The guidance contained in this ruling is affected by subsequent law changes.

BPR 089​Waiver of certain rights connected to shares
BPR 088​Contributed capital of a foreign limited liability co-operative
BPR 087​Capital gains tax consequences arising from restructuring activities involving trusts
BPR 086​Application of relevant legislation where two parties conduct mining operations in terms of an unincorporated joint venture agreement
BPR 085

​Taxation aspects of income derived by non South African residents from employment in South Africa

The guidance in respect of the third ruling has changed and should not be relied on.

BPR 084​The ‘group of companies’ concept for the purposes of section 45(4)
BPR 083​Capital gains tax implications on the conversion of a company through the amendment of its incorporation documentation
BPR 082Permanent establishment and royalties
BPR 081

Determination of the value of the taxable benefit of residential accommodation

The guidance contained in this ruling is affected by subsequent law changes.


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