BPR 81-100

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 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 Some guidance contained in this ruling is affected by subsequent law changes and new legislation. Refer section 64B and paragraph 12(5).
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 082	Permanent establishment and royalties The guidance contained in this ruling is affected by subsequent law changes and new legislation.
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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