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A Binding Class Ruling (BCR) is issued in response to an application and clarifies how the Commissioner would interpret and apply the provisions of the tax laws relating a specific proposed transaction.
Applicable Legislation
  • Any tax Act administered by SARS as referred to in section 4 of the South African Revenue Service Act, 1997, excluding the Customs and Excise Act, 1964

Also see the Register of all Binding Class Rulings. (The register comprises an overview of all Binding Class Rulings, followed by Binding Class Rulings organised according to tax types.)


NumberApplicable Legislation​Subject
​​BCR 021​Income Tax Act, 1962​Shares in a particular share option scheme to be rendered restricted equity instruments and the date on which those shares vest in a taxpayer
BCR 022​Income Tax Act, 1962​Potential double taxation of profits attributable to protected cell companies
BCR 023​Income Tax Act, 1962​Tax consequences resulting from the demerger of a Swiss depository company
​​BCR 024​Income Tax Act, 1962​Securities lending transactions – ‘Short selling’ of debt securities
BCR 025​Income Tax Act, 1962​​Income tax implications for employees or senior executives in relation to a share option plan or share appreciation rights plan

Replaced on 1 September 2014 to provide for textual changes and to correct “exercise” to “vesting” in the section 8C formulae – refer to the first and second bullet points in paragraph 7.  The original ruling issued to the Applicant and the Participant did not contain the mentioned error.
BCR 026​​Income Tax Act, 1962​Tax status of bursaries awarded to students
BCR 027​Income Tax Act, 1962​​Tips held for safekeeping by employers and subsequently paid over to employees at regular intervals
BCR 028​Income Tax Act, 1962​​Market value of a share immediately after a dividend distribution
​​BCR 029​Income Tax Act, 1962​Deductibility of contingent liabilities taken over when buying the assets and liabilities of another company within the same group of companies
​BCR 030​Income Tax Act, 1962​​Equity instruments acquired in terms of a share value incentive plan
​​BCR 031​Income Tax Act, 1962​Income distributed by a discretionary trust and benefit units allocated to beneficiaries by virtue of employment

The guidance contained in this ruling is affected by subsequent law changes.
​​BCR 032​Income Tax Act, 1962

Securities Transfer Tax Act, 2007
​Distribution of certain shares to certain foreign shareholders as a result of restructuring
BCR 033​Income Tax Act, 1962​Conversion of a public company to a private company
BCR 034​Income Tax Act, 1962​​Taxation of exchange traded notes
BCR 035​Income Tax Act, 1962

Securities Transfer Tax Act, 2007
​Tax implications arising from the conversion of par value shares to no par value shares
BCR 036​Income Tax Act, 1962​Reserves of a collective investment scheme in securities and the distribution thereof to unitholders
​​BCR 037​Income Tax Act, 1962

Securities Transfer Tax Act, 2007
​Distribution of shares in an unbundling transaction
​​BCR 038​Income Tax Act, 1962

Securities Transfer Tax Act, 2007
​Exchange of one restricted equity instrument for another
BCR 039​Income Tax Act, 1962​Reduction of an STC credit and sections 64G(2)(a) and 64H(2)(a) declarations
​​BCR 040​Income Tax Act, 1962​Investors acquiring rights in a completed film


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