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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.
 
​Number​Subject
BPR 101Securities transfer tax – Asset-for-share transaction
BPR 102Registration of an external company and identifying a permanent establishment
BPR 103​Share incentive scheme
BPR 104​Intra-group transfer of shares as a result of restructuring
BPR 105​Tax implications for a resident relating to a single premium whole life insurance polic issued by an offshore insurer
BPR 106​Application of section 24C to a maintenance trust
BPR 107​Recoupment of lease premium and rental amounts previously allowed as deductions in respect of a leased property
BPR 108​Issue of redeemable preference shares from reserves available for distribution
BPR 109​Loan granted with embedded option
BPR 110​Toll manufacturing agreement and the attribution of the global sales of South African manufactured products to a foreign business establishment
BPR 111​Research and development expenditure paid to a fellow group company which is not a resident of South Africa
​BPR 112​Interposing a co-operative between a South African holding company and its foreign subsidiaries
BPR 113​Expenditure associated with broad based black economic empowerment
BPR 114​Loan facilities raised by a foreign permanent establishment from which deposits and advances are made
BPR 115 
New!
​Incentive rewards paid to independent sales persons
BPR 116​Distribution to be received by a resident beneficiary from a trust that is not a resident and the subsequent donation thereof by the beneficiary to another trust that is also not a resident
BPR 117​Obligation to deduct or withhold employee’s tax in respect of a share option
BPR 118​Withholding dividends tax
BPR 119​Transfer of amounts contributed to a foreign pension fund to a South African retirement annuity fund
BPR 120​The interaction between sections 45 and 24J in the transfer of interest-bearing receivables under the corporate rules

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