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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 341​Distribution of a bank account as dividend in specie
BPR 342
​Donation by a resident to a foreign trust of property received from another foreign trust
BPR 343​Donations tax implications subscribing for shares at a discount
​​BPR 344​Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests
BPR 345​Asset-for-share transactions followed by an unbundling transaction and a sale of shares to a third party
​​BPR 346​Tax implications resulting from the elimination of intra-group loans
BPR 347​When the temporary setting aside of voluntary liquidation proceedings will not jeopardise roll-over relief
BPR 348​Income tax consequences for a public benefit organisation lending funds to qualifying entrepreneurs
BPR 349​Acquisition of equity shares in non-resident REIT
BPR 350​Vesting of a capital gain in a trust beneficiary and deferral of its payment
BPR 351​Waiver of an intra group loan to, and subsequent liquidation distribution by a subsidiary
BPR 352​Taxation of employees participating in an option programme
​​BPR 353​Linear adjustment of gross sales of unrefined mineral resource
BPR 354​Cash grants to an employee incentive trust and the transfer of share awards to qualifying employees
BPR 355​Accrual of pension payments to a resident from a foreign pension fund
BPR 356​Preference share – hybrid equity instrument and third-party backed share
BPR 357​Donations to a foreign trust of property situated outside the Republic
​​BPR 358​Amalgamation of short and long-term insurers
​​​BPR 359​Transfer of reinsurance business from a resident company to a local branch of a foreign company
BPR 360​Internal restructure followed by a disposal of shares to a BBBEE investor

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