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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.

BPR 181

Withholding tax on interest in relation to a foreign government

​BPR 182

​Waiver of debt that funded mining capital expenditure

BPR 183

​Employee Housing Scheme

BPR 184

​Asset-for-Share Transaction

BPR 185

​Corporate Rules: Disposal of assets and liabilities as part of a group restructure 

BPR 186

​Asset-for-Share transaction between a resident private company and a collective investment scheme (CIS) in securities   

BPR 187

​Waiver of an intra-group loan that funded the acquisition of a mining operation

​BPR 188

​Conversion of a public benefit organisation to a for-profit company

BPR 189

​Acquisition of shares subject to suspensive conditions

​BPR 190

​Notional Funding Arrangement: The issue and potential repurchase of ordinary shares 

​BPR 191

​Refinancing of debt through preference share funding

​BPR 192

​Cross border interest-free loan and withholding tax on interest 

BPR 193

​Debt reduction by way of set-off

BPR 194

​Disposal of shares through a share buy-back and a donation

​BPR 195

​Securities transfer tax exemption where election has been made that section 42 will not apply

BPR 196


Employees’ Tax: Monthly pension benefits in respect of foreign services rendered​ 

Note: The guidance contained in this ruling is affected by subsequent law changes.

​BPR 197

​Exemption from donations tax and net value of an estate

​BPR 198

​Distribution of a debit loan account in anticipation of deregistration of a company

BPR 199

​Exemption from income tax of dividends received by virtue of restricted equity instruments

​BPR 200

​Source of income of commission payable to non-resident junket agents 

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