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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 121Secondary tax on companies or dividends tax
BPR 122Transfer of a business of a company as a going concern to its holding company as a result of an amalgamation or merger transaction
BPR 123​Fibre optic cable to be used for electronic communications
BPR 124​Repayment of shareholders’ loans from proceeds of a new issue of redeemable preference shares
BPR 125​Vesting by discretionary trust of dividend rights to the beneficiary of the trust
BPR 126​​Disposal of a business and investment shares as a result of restructuring, and the distribution of certain shares to shareholders
​BPR 127​Relief from double taxation of foreign income
BPR 128​Disposal of equity shares in a foreign company
BPR 129​Beneficial owner of dividends
BPR 130​Sale of mining rights and the respective base cost of each mining right
BPR 131​Vesting date of a restricted equity instrument
BPR 132​Disposal of a business as a going concern by a trust to a company in exchange for shares in the company
BPR 133​Transfer of a residence out of a company to a natural person
BPR 134​Exemption under section 10B(2)(a) in relation to a foreign dividend that is deemed to be received by a person who is a resident
BPR 135​Improvements effected on land in terms of a long term lease
​BPR 136​Taxation of subsistence allowances paid to employees
BPR 137​Sale of a business in terms of an intra-group transaction
BPR 138​Subscription for shares at nominal values coupled to a repurchase agreement at the same nominal values
BPR 139
Disposal of assets by a recreational club​
BPR 140​Unbundling transactions

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