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.
Determination of group of companies
|STT treatment of the proposed transfer of listed shares to the applicant in order to hedge its exposure under over-the-counter derivative transactions|
|BPR 372||Withholding tax on foreign royalties|
|BPR 371||Public benefit activities carried on for the benefit of the general public|
|BPR 370||Registration of shares in the name of beneficial holder|
|BPR 369||Deductibility of interest incurred pursuant to liquidation of company|
|BPR 368||Payments made pursuant to an agreement relating to a permission to occupy|
|BPR 367||Employment tax incentive|
|BPR 366||Distribution in specie of shares|
|BPR 365||Interpretation and application of the de-grouping provision in section 45(4)(b)|
|BPR 364||Extraordinary dividend followed by the dilution of shareholders’ interest|
|BPR 363||Value of a supply of services|
|BPR 362||Transfer of assets between share incentive trusts|
|BPR 361||Asset-for-share transaction followed by an unbundling transaction, the issue of capitalisation redeemable preference shares and the sale of shares to a third party|