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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 041Impact of the de-grouping provisions where the transferror in the first intra-group transaction and the transferee in the second intra-group transaction are the same company
BPR 042
​Determination of who qualifies as a ‘film owner’ for purposes of section 24F
The guidance contained in this ruling is affected by subsequent law changes
BPR 043​Private use of a company motor vehicle
BPR 044​Foreign business establishment exclusion
BPR 045​Deductibility of conditional interest incurred in terms of a loan
BPR 046​Accrual of an unclaimed retirement fund (lump sum) benefit
BPR 047​Agency income earned by a controlled foreign company to be excluded from its net income
BPR 048
​Deeming a place of business to be a ‘foreign business establishment’ as envisaged in section 9D(1)
The guidance contained in this ruling is affected by subsequent law changes
BPR 049
​Nature of proceeds received for the lease of property in terms of a 99 year lease
The guidance contained in this ruling is affected by subsequent case law
BPR 050​Cash grants made by an employer to share-incentive scheme trusts and their deductibility for tax purposes
BPR 051​Environmental expenditure allowances
BPR 052​Repatriation of profits in the form of foreign dividends paid by a foreign subsidiary to a resident company which was previously exempt from income tax

The guidance contained in this ruling may be affected by subsequent law changes 
BPR 053​Value-added tax implications arising from the construction of buildings by an entity and the subsequent donation of such buildings to another entity
​BPR 054​Corporate rules – amalgamation transactions
BPR 055​Application of the definition of ‘dividend’ to the redemption of a participatory interest by a foreign collective investment scheme
BPR 056​Taxability of income and capital gains in the hands of vesting beneficiaries whether a resident or not (Income Tax Act, 1962)
BPR 057​Interest incurred on a loan obtained to acquire the business of a company as a going concern through the acquisition of the shares of the company
BPR 058​Acquisition of shares as a result of company restructuring and interest on a loan created in the restructuring process
BPR 059​Corporate rules – Transfer of the assets of a businesses conducted by a sole proprietor to companies and close corporations
BPR 060​Short sale transactions and securities lending arrangements

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