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 321​Surplus retirement fund assets
​BPR 322
​Equity linked note
BPR 322 was replaced on 31 July to provide for textual changes. For clarity, refer to paragraph 4, last paragraph and deletion of the rulings under paragraph 6b) and 6c).
​BPR 323​Debt reduction by means of set-off
BPR 324​Disposal and acquisition of shares by a public benefit organisation
​BPR 325​Liquidation distribution and amalgamation transaction between non-resident companies
BPR 326​Group restructuring transactions in a foreign jurisdiction
BPR 327​Tax implications of a group restructuring
BPR 328​Consecutive asset-for-share transactions
BPR 329​Tax consequences of intra-group restructuring and subsequent sale of assets to third party
​​BPR 330​Distributions of dividends and other amounts from a trust to beneficiaries on termination of their employment
​​​BPR 331​De-grouping charge
​​​​BPR 332​Unbundling and subsequent issue of listed shares by non-resident subsidiary of resident holding company
BPR 333​​Venture capital company – Investment in farming operations
​​BPR 334​Waiver of loan claims by the settlor of a trust
​​​BPR 335​STT exemption for foreign governments
​​​BPR 336​Liquidation Distribution
​​​BPR 337​Amalgamation transactions involving the assumption of liabilities only
​​​​​BPR 338​Donations of money made to a public benefit organisation at a fundraising event
​​​​​​BPR 339​Transfer of listed shares to a collective investment scheme in exchange for participatory interests
​​​​​​BPR 340
​Share buy-back at nominal value

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