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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 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 061​Income Tax Act, 1962​Foreign return of capital
​BCR 062​Income Tax Act, 1962​Research and development conducted on behalf of a taxpayer
BCR 063
​Income Tax Act, 1962​Income tax implications of settlement agreement
​​BCR 064​Securities Transfer Tax Act, 2007​Transfer of a security that constitutes a participatory interest in a collective investment scheme
​BCR 065​Income Tax Act, 1962​Post-retirement medical aid benefits

The guidance contained in this ruling is affected by subsequent law changes
​​BCR 066​Income Tax Act, 1962 and
Securities Transfer Tax Act, 2007
​Tax consequences for recipients of shares in an unbundled company
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 068​Income Tax Act, 1962​Surplus retirement fund assets
​BCR 069​Income Tax Act, 1962​Employee share ownership plan
BCR 070

​Income Tax Act, 1962

Securities Transfer Tax Act, 2007

​Recipients of shares in an “unbundled” company
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 072​Income Tax Act, 1962​Deductibility 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 073​Income Tax Act, 1962​Dividends: When the “qualifying purpose” definition must be satisfied
​BCR 074​Income Tax Act, 1962​Treaty relief – Authorised contractual scheme

BCR ​075​​

​Income Tax Act, 1962​ Settlement of post-retirement medical aid and retirement gratuity benefits

BCR 076

​Income Tax Act, 1962​Cancellation of units in foreign collective investment schemes pursuant to their corporate re-domiciliation

BCR 077

Income Tax Act, 1962

Capital gains tax consequences of in specie distribution by company to its shareholders

BCR 078

Income Tax Act, 1962

Employee share incentive scheme – shares in a foreign company


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