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 to 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.)

  
Number​Applicable Legislation​Subject
BCR 080
New!
Income Tax Act, 1962

Tax implications for resident beneficiaries of a foreign pension trust

BCR 079Income Tax Act, 1962Cancellation of share exchange
BCR 078Income Tax Act, 1962Employee share incentive scheme – shares in a foreign company
BCR 077Income Tax Act, 1962Capital gains tax consequences of in specie distribution by company to its shareholders
BCR 076Income Tax Act, 1962​Cancellation of units in foreign collective investment schemes pursuant to their corporate re-domiciliation
BCR ​075Income Tax Act, 1962Settlement of post-retirement medical aid and retirement gratuity benefits
BCR 074Income Tax Act, 1962Treaty relief – Authorised contractual scheme
BCR 073Income Tax Act, 1962Dividends: When the “qualifying purpose” definition must be satisfied
BCR 072Income Tax Act, 1962Deductibility of employment related expenditure, incurred as part of a B-BBEE ownership transaction and the PAYE treatment of interest-free loan to a share trust
BCR 071

Income Tax Act, 1962

Securities Transfer Tax Act, 2007

Transfer of portfolio investments by foreign pension funds to an authorised contractual scheme
BCR 070

Income Tax Act, 1962

Securities Transfer Tax Act, 2007

​Recipients of shares in an “unbundled” company
BCR 069Income Tax Act, 1962Employee share ownership plan
BCR 068Income Tax Act, 1962Surplus retirement fund assets
BCR 067

Income Tax Act, 1962

Value-Added Tax Act, 1991

Tax consequences for members arising out of conversion of association to private company
BCR 066

Income Tax Act, 1962

Securities Transfer Tax Act, 2007

Tax consequences for recipients of shares in an unbundled company
BCR 065Income Tax Act, 1962Post-retirement medical aid benefits

The guidance contained in this ruling is affected by subsequent law changes
BCR 064Securities Transfer Tax Act, 2007Transfer of a security that constitutes a participatory interest in a collective investment scheme
BCR 063Income Tax Act, 1962​Income tax implications of settlement agreement
BCR 062Income Tax Act, 1962Research and development conducted on behalf of a taxpayer
BCR 061​Income Tax Act, 1962​Foreign return of capital
 

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