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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 061Application of the definitions of ‘company’ and ‘controlled foreign company’ with regard to a foreign limited partnership 
BPR 062​Settlement of a loan by an offshore holding company in favour of its South African subsidiary without requiring any quid pro quo
BPR 063​​Interest incurred on loans obtained to acquire the shares of a company as opposed to acquiring the business of the company
BPR 064​Employees’ tax – Annuity payments from one long-term insurance company to another
BPR 065​Determination of residency for South African income tax purposes in the context of the term ‘ordinarily resident’
BPR 066​Deductibility of interest incurred on loans obtained to acquire the businesses of a group of companies as going concerns through the acquisition of the shares in a holding company
BPR 067​Foreign business establishment: Sharing of employees, equipment and facilities amongst controlled foreign companies which are part of the same group of companies
BPR 068​Classification of the extraction of clay from the soil
BPR 069​VAT implications with regard to the supply of services in respect of which mitigation costs and mitigation services costs are received, the time of supply of such services and the deduction of VAT charged on such services as input
BPR 070​Capital gains tax implications in respect of the transfer of trust funds held in an offshore trust to newly formed offshore discretionary trust
BPR 071​Improvements effected on leasehold property
BPR 072​VAT implications with regard to qualified goods imported for processing and the subsequent exportation of the end products
BPR 073​Extinction of inter-company loans as a result of voluntary winding-up
BPR 074​Date upon which shares vest in a taxpayer and related interest expense
BPR 075​Lump sum benefit to be paid from a deemed public sector fund and the application of Formula C
BPR 076​Nature of income in the hands of a vested beneficiary of a trust
BPR 077​Transfer of compensation award granted to an incapacitated person to a trust to be administered by trustees for the benefit of that person
BPR 078​Income tax consequences of leasehold improvements for both the lessor and the lessee
​BPR 079​Income tax implications for the land owner and the developer relating to the establishment of a residential township development in terms of lease agreements
BPR 080​Donation of shares

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