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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 081Determination of the value of the taxable benefit of residential accommodation
BPR 082Permanent establishment and royalties
BPR 083​Capital gains tax implications on the conversion of a company through the amendment of its incorporation documentation
BPR 084​The ‘group of companies’ concept for the purposes of section 45(4)
BPR 085​Taxation aspects of income derived by non South African residents from employment in South Africa
BPR 086​Application of relevant legislation where two parties conduct mining operations in terms of an unincorporated joint venture agreement
BPR 087​Capital gains tax consequences arising from restructuring activities involving trusts
BPR 088​Contributed capital of a foreign limited liability co-operative
BPR 089​Waiver of certain rights connected to shares
BPR 090​Royalty income attributable to a foreign business establishment of a controled foreign company
BPR 091​Securities lending transaction
BPR 092​Possible recoupment of rental paid on the subsequent acquisition of the leased property by the lessee
BPR 093​Deductibility of environmental expenditure subsequently incurred in respect of asset that have been acquired in an asset-for-share transaction
BPR 094​Charges incurred in relation to the acquisition of trading stock
BPR 095​Adequate consideration as contemplated under section 58(1)
​BPR 096​Group restructuring transactions and possible relief measures
BPR 097​Capital gains tax liability in relation to assets of a trust which vest in the hands of the vesting beneficiaries
BPR 098​Capital gain or loss on ceded policies
BPR 099​Transfer of beneficial ownership of South African listed shares under a ‘riskless principal’ transaction
BPR 100​Date of accrual of short-term insurance premiums payable in terms of a guarantee policy, suretyship provided to the Master of the High Court and the time of supply of the guarantee policy

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