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