Legal Counsel – Rulings – Document List

BCR Rulings

Legal-R-BCR-2022-03 – BCR 081 Hybrid equity interest or third-party backed share

Legal-R-BCR-2022-03 – BCR 080 Tax implications for resident beneficiaries of a foreign trust

Legal-R-BCR-2022-02 – BCR 079 Cancellation of share exchange

Legal-R-BCR-086 – Waiver of debt by an employer relating to the unwinding of a share purchase scheme

Legal-R-BCR-085 – En commandite partnerships investing in photovoltaic solar energy plants

Legal-R-BCR-084 – Transfer of funds held in trust to a “beneficiary fund”

Legal-R-BCR-083 – Simultaneous unbundling of shares held in more than one listed company

Legal-R-BCR-082 – Deductibility of mining rehabilitation insurance premiums

Legal-IntR-R-BCR-088 – En commandite partners investing in solar assets

Legal-IntR-R-BCR-087 – Consequences for shareholders upon termination of a venture capital company

LAPD-IntR-R-BCR-2020-01 – BCR070 Recipients of shares in an unbundled company

LAPD-IntR-R-BCR-2018-10 – BCR 069 Employee share ownership plan

LAPD-IntR-R-BCR-2018-09 – BCR 068 Surplus retirement fund assets

LAPD-IntR-R-BCR-2018-08 – BCR 067 Tax consequences for members arising out of conversion of association to private company

LAPD-IntR-R-BCR-2018-07 – BCR 066 Tax consequences for recipients of shares in an unbundled company

LAPD-IntR-R-BCR-2018-06 – BCR 065 Post-retirement medical aid benefits

LAPD-IntR-R-BCR-2018-05 – BCR 064 Participatory interest in a collective investment scheme

LAPD-IntR-R-BCR-2018-04 – BCR 063 Income Tax implication of settlement agreement

LAPD-IntR-R-BCR-2018-03 – BCR 062 Research and Development conducted on behalf of a taxpayer

LAPD-IntR-R-BCR-2018-02 – BCR 061 Foreign return on capital

LAPD-IntR-R-BCR-2018-01 – BCR 060 Consequences employee share trust disposing underlying shares distributing net proceeds

LAPD-IntR-R-BCR-2017-02 – BCR059 Asset for share transaction involving a foreign collective investment scheme

LAPD-IntR-R-BCR-2017-01 – BCR058 Consequences for beneficiaries on unwinding of share incentive scheme

LAPD-IntR-R-BCR-2016-09 – BCR057 Section 12J(2) deduction by partners

LAPD-IntR-R-BCR-2016-08 – BCR056 Amalgamation of portfolios of declared hedge fund collective investment schemes

LAPD-IntR-R-BCR-2016-07 – BCR055 Income tax and VAT consequences of a customer loyalty scheme

LAPD-IntR-R-BCR-2016-06 – BCR054 Employer provided accommodation

LAPD-IntR-R-BCR-2016-05 – BCR053 Programme of activities of a clean development mechanism project

LAPD-IntR-R-BCR-2016-04 – BCR052 Income tax and securities transfer tax consequences following an unbundling transaction

LAPD-IntR-R-BCR-2016-03 – BCR051 Taxation of employees participating in a perpetuity employee share incentive scheme

LAPD-IntR-R-BCR-2016-02 – BCR050 Tax consequences for unitholders in a REIT of an amalgamation transaction

LAPD-IntR-R-BCR-2016-01 – BCR049 Deductibility of insurance premiums environmental maintenance

LAPD-IntR-R-BCR-2014-07 – BCR048 Deductibility of expenditure incurred by a portfolio of a collective investment scheme

LAPD-IntR-R-BCR-2014-06 – BCR047 Limitation of Dividend Exemption

LAPD-IntR-R-BCR-2014-05 – BCR046 Dividends distributed by foreign companies

LAPD-IntR-R-BCR-2014-04 – BCR045 Post Retirement Medical Aid Benefits

LAPD-IntR-R-BCR-2014-03 – BCR044 Repurchase NonRedeemable NonParticipating Preference Shares

LAPD-IntR-R-BCR-2014-02 – BCR043 Antecedent cession of rights to future PRCCs in APDP

LAPD-IntR-R-BCR-2014-01 – BCR042 Preferred Securities issued by Foreign Registered Company

LAPD-IntR-R-BCR-2013-03 – BCR041 Dividends Distributed Foreign Company

LAPD-IntR-R-BCR-2013-02 – BCR040 Investors acquiring rights in a completed film

LAPD-IntR-R-BCR-2013-01 – BCR039 Reduction STC credit sections 64G and 64H declarations

LAPD-IntR-R-BCR-2012-38 – BCR038 Exchange Restricted Equity Instrument

LAPD-IntR-R-BCR-2012-37 – BCR037 Distribution shares Unbundling Transaction

LAPD-IntR-R-BCR-2012-36 – Reserves Collective Investment Scheme Securities Distribution

LAPD-IntR-R-BCR-2012-35 – Tax Implications Conversion Par Value Shares

LAPD-IntR-R-BCR-2012-34 – Taxation Exchange Trade Notes

LAPD-IntR-R-BCR-2012-33 – Conversion Public to Private Company

LAPD-IntR-R-BCR-2012-32 – Distribution Shares Foreign Shareholders Result Restructuring

LAPD-IntR-R-BCR-2012-31 – Income Distributed Discretionary Trust Benefits

LAPD-IntR-R-BCR-2012-30 – Equity Instruments Acquired Share Value Incentive Plan

LAPD-IntR-R-BCR-2012-29 – Deductibility Contingent Liabilities Taken Over

LAPD-IntR-R-BCR-2012-28 – Market Value Share Immediately After Dividend Distribution

LAPD-IntR-R-BCR-2012-27 – Tips Held Safekeeping Paid Over Regular Intervals

LAPD-IntR-R-BCR-2012-26 – Tax Status Bursaries Students

LAPD-IntR-R-BCR-2012-25 – Tax Implications Employees Senior Executives Share Option Plan Appreciation Rights Plan

LAPD-IntR-R-BCR-2012-24 – Securities Lending Transactions Short Selling Debt Securities

LAPD-IntR-R-BCR-2012-23 – Tax Consequences Demerger Swiss Depository Company

LAPD-IntR-R-BCR-2012-22 – Potential Double Taxation Profits Protected Cell Companies

LAPD-IntR-R-BCR-2012-21 – Shares Share Option Scheme Restricted Equity Instruments Date

LAPD-IntR-R-BCR-2012-20 – Transfer Pension Provident Fund Contributions

LAPD-IntR-R-BCR-2012-19 – Accrual Date Liquidation Benefit

LAPD-IntR-R-BCR-2012-18 – Overseas Incentive Trips Employees Business and Private Elements

LAPD-IntR-R-BCR-2012-17 – Creation Permanent Establishment Foreign Partnership Business RSA

LAPD-IntR-R-BCR-2012-16 – CGT Redesignation Preference Shares

LAPD-IntR-R-BCR-2012-15 – Repealed Legislation

LAPD-IntR-R-BCR-2012-14 – Deductibility Interest Loan Restricted Equity Instruments Share Purchase Scheme

LAPD-IntR-R-BCR-2012-13 – Nature Dividend Income Discretionary Trust

LAPD-IntR-R-BCR-2012-12 – Equity Instrument Foreign Stock Exchange Tax Implications

LAPD-IntR-R-BCR-2012-11 – Accrual Conditional Award

LAPD-IntR-R-BCR-2012-10 – Distribution Pension Fund Surplus

LAPD-IntR-R-BCR-2012-09 – Foreign Share Buy Backs

LAPD-IntR-R-BCR-2012-08 – Tax Consequences Annuity Policies Post Retirement Medical Aid Subsidy

LAPD-IntR-R-BCR-2012-07 – Conversion Public Sector Pension Funds to Closed Defined Benefit and Contribution Fund

LAPD-IntR-R-BCR-2012-06 – Deduction Levy Payments Research Development Other Taxpayer On Behalf

LAPD-IntR-R-BCR-2012-05 – Discretionary Lump Sum Payments Pensioners Rules Pension Fund

LAPD-IntR-R-BCR-2012-04 – Distributions Collective Investment Scheme Reinvested

LAPD-IntR-R-BCR-2012-03 – Distribution Actuarial Surplus Members Former and Active Retirement Fund

LAPD-IntR-R-BCR-2012-02 – Expenditure Corporate Social Investment Programmes

LAPD-IntR-R-BCR-2012-01 – Definition Equity Instrument

INTR-R-BCR-2022-01 – BCR 078 Employee share incentive scheme – shares in a foreign company

IntR-R-BCR-2021-01 – BCR 077 Capital gains tax consequences of in specie distribution by company to its shareholders

IntR-R-BCR-2020-07 – BCR076 Cancellation of units in foreign collective investment schemes

IntR-R-BCR-2020-06 – BCR075 Settlement of post-retirement medical aid and retirement gratuity benefits

IntR-R-BCR-2020-05 – BCR074 Treaty relief – authorised contractual scheme

IntR-R-BCR-2020-04 – BCR073 Dividends when the qualifying purpose definition must be satisfied

IntR-R-BCR-2020-03 – BCR072 Deductibility of employment related expenditure as part of BBBEE ownership transaction

IntR-R-BCR-2020-02 – BCR071 Transfer of portfolio investments by foreign pension funds

BGR Rulings

Legal-R-BGR-63 – Further particulars prescribed by the Commissioner under section 20(8A)(c)

Legal-R-BGR-61 – BGR Securities transfer tax implications on re-use of collateral

Legal-R-BGR-59 – Calculation of VAT for table games of chance

Legal-R-BGR-47 – Meaning of month for employers remunerating employees on a weekly or fortnightly basis

Legal-R-BGR-44 – Meaning of 160 hours for purposes of section 4(1)(b)

Legal-R-BGR-28 – Electronic services – Requirements relating to credit and debit notes exchange rates and advertised or quoted prices

Legal-IntR-R-BGR-72 – Particulars to be contained in a credit note for a valid deduction under section 16(3)(a)(v) for prepaid vouchers

Legal-IntR-R-BGR-71 – Section 18A Receipt – Donation of Property in Kind

Legal-IntR-R-BGR-70 – Issue of a Single Section 18A Receipt to a Donor Taxpayer for Multiple Bona Fide Donations

Legal-IntR-R-BGR-69 – Documents and records to be retained and maintained by agent under section 54(2C) and (3)

Legal-IntR-R-BGR-68 – Acceptable Documentation for Input Tax on Upward Adjustments on Imports

Legal-IntR-R-BGR-67 – Income Tax Exemption of a Grant Received under the Clothing Textiles Footwear and Leather Growth Programme

Legal-IntR-R-BGR-66 – Value-added tax implications of overpayments on the importation of goods

Legal-IntR-R-BGR-65 – Value-added tax treatment of rounding difference in cash transactions

Legal-IntR-R-BGR-64 – Temporary application of new dwellings for exempt supplies simultaneously held by developers for taxable purposes

Legal-IntR-R-BGR-62 – Value-added tax implications of securities lending arrangements

Legal-IntR-R-BGR-16 – Standard turnover-based method of apportionment

Legal-IntR-R-BGR-14 – VAT treatment of specific supplies in the short-term (non-life) insurance industry

LAPD-IntR-R-BGR-Arc-2022-50 – BGR51 Cancellation of registration of a foreign electronic services supplier archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-49 – BGR49 The supply and importation of sanitary towels (pads) archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-48 – BGR46 Supply of brown bread archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-47 – BGR45 Supply of potatoes archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-46 – BGR41 VAT treatment of non-executive directors archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-45 – BGR39 VAT treatment of municipal affected by changes to municipal boundaries archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-44 – BGR38 The VAT treatment of the supply and importation of vegetables and fruit archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-43 – BGR35 The VAT treatment of the supply and importation of frozen potato products archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-42 – BGR34 Management of superannuation schemes – long-term insurers archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-41 – BGR33 The value-added tax treatment of the supply or importation of vegetable oil archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-40 – BGR31 Interest on late payment of benefits archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-39 – BGR29 – Unbundling transactions – Meaning ‘as at the end of the day after that distribution’ archived 310322

LAPD-IntR-R-BGR-Arc-2022-38 – BGR28 Electronic services archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-37 – BGR26 The value-added tax treatment of the supply and importation of herbs archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-36 – BGR25 (Issue 2) Exemption Foreign pensions archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-35 – BGR25 – Exemption – foreign pensions archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-34 – BGR24 S 18A(2) receipt for a deduction as contemplated in s 37C(3) and (5) archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-33 – BGR20 (Issue 2) Interpretation of the term ‘substantially the whole’ archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-32 – BGR20 Interpretation of the expression ‘substantially the whole’ archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-31 – BGR19 Approval to end a tax period on a day other than the last day of a month archived 31 Mar 2022

LAPD-IntR-R-BGR-Arc-2022-30 – BGR18 Zero-rating various types of dates archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-28 – BGR15 Recipient-Created Tax Invoices, Credit and Debit Notes archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-27 – BGR14 (Issue 2) VAT treatment of specific supplies in the short-term insurance industry archived 31 Mar 2022

LAPD-IntR-R-BGR-Arc-2022-26 – BGR14 VAT treatment of specific supplies in the short-term insurance industry archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-25 – BGR13 (Issue 2) Calculation of VAT for certain betting transactions archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-24 – BGR13 Calculation of VAT for certain betting transactions archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-23 – BGR12 (Issue 2) Input tax acquisition non taxable supply second hand motor vehicles archived31032022

LAPD-IntR-R-BGR-Arc-2022-22 – BGR12 Input tax acquisition non-taxable supply second-hand motor vehicles by motor dealers archived 31032022

LAPD-IntR-R-BGR-Arc-2022-21 – BGR11 (Issue 2) Use of an exchange rate archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-20 – BGR11 Use of an exchange rate archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-19 – BGR10 Apportionment methodology Category B Municipalities archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-18 – BGR9 (Issue 3) Taxes on income and similar taxes for purposes of SA DTAs archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-17 – BGR9 (Issue 2) Taxes on income and similar taxes for purposes of SA DTAs archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-16 – BGR9 Taxes on income and similar taxes for purposes of SA DTAs archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-15 – BGR8 Application of the Principles Enunciated by the Brummeria Case archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-14 – BGR7 (Issue 3) Wear-and-tear or depreciation allowance archived 30 March 2022

LAPD-IntR-R-BGR-Arc-2022-13 – BGR7 (Issue 2) Wear-and-tear or depreciation allowance archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-12 – BGR7 Wear-and-tear or depreciaton allowance archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-11 – BGR6 Discounts, rebates and incentives in the fast moving consumable goods industry archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-10 – BGR4 (Issue 2) Apportionment methodology to be applied by Category A and B Municipalities archived 31032022

LAPD-IntR-R-BGR-Arc-2022-09 – BGR4 Apportionment methodology to be applied by Category A Municipalities archived 31 March 2022

LAPD-IntR-R-BGR-Arc-2022-08 – BGR3 Transitional Arrangements Municipalities archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-07 – BGR52 Timeframe export of goods by vendors and qualifying purchasers affected by COVID-19 archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-06 – BGR36 Circumstances prescribed by the Commissioner for the application of section 162g archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-05 – BGR34 (Issue 2) Management of superannuation schemes long term insurers archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-04 – BGR13 (Issue 3) VAT Calculation Betting Transactions archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-03 – BGR12 (Issue 3) Input Tax Acquisition NonTaxable Supply SecondHand Motor Vehicles archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-02 – BGR2 General Written Rulings Decisions archived 28 March 2022

LAPD-IntR-R-BGR-Arc-2022-01 – BGR1 VAT Rulings archived 28 March 2022

LAPD-IntR-R-BGR-ARC-2020-33 – BGR 51 – Cancellation of registration of a foreign electronic services supplier 4 June 2019

LAPD-IntR-R-BGR-ARC-2020-32 – BGR 49 – The supply and importation of sanitary towels (pads) 15 March 2019

LAPD-IntR-R-BGR-ARC-2020-31 – BGR 46 – Supply of brown bread 27 November 2017

LAPD-IntR-R-BGR-ARC-2020-30 – BGR 45 – Supply of potatoes 1 November 2017

LAPD-IntR-R-BGR-ARC-2020-29 – BGR 41 – VAT treatment of non-executive directors 10 February 2017

LAPD-IntR-R-BGR-ARC-2020-28 – BGR 39 – VAT treatment of municipal affected by changes to municipal boundaries 27 Jan 2017

LAPD-IntR-R-BGR-ARC-2020-27 – BGR 38 – VAT treatment of the supply and importation of vegetables and fruit 23 January 2017

LAPD-IntR-R-BGR-ARC-2020-26 – BGR 37 – Zero-rating of international travel insurance 12 December 2016

LAPD-IntR-R-BGR-ARC-2020-25 – BGR 35 – VAT treatment of the supply and importation of frozen potato products 27 May 2016

LAPD-IntR-R-BGR-ARC-2020-24 – BGR 34 – Management of superannuation schemes – long-term insurers 14 April 2016

LAPD-IntR-R-BGR-ARC-2020-23 – BGR 33 – VAT treatment of the supply or importation of vegetable oil 24 March 2016

LAPD-IntR-R-BGR-ARC-2020-22 – BGR 31 – Interest on late payment of benefits 4 March 2016

LAPD-IntR-R-BGR-ARC-2020-21 – BGR 29 – Unbundling – Meaning ‘as at the end of the day after that distribution’ 20 Aug 2015

LAPD-IntR-R-BGR-ARC-2020-20 – BGR 28 – Electronic services 26 March 2015

LAPD-IntR-R-BGR-ARC-2020-19 – BGR 26 – The VAT treatment of the supply and importation of herbs 12 March 2015

LAPD-IntR-R-BGR-ARC-2020-17 – BGR 24 – Section 18A(2) receipt for a deduction in section 37C(3) and (5) 2 September 2014

LAPD-IntR-R-BGR-ARC-2020-16a – BGR 20 (Issue 2) – Interpretation of the term ‘substantially the whole’ 20 January 2016

LAPD-IntR-R-BGR-ARC-2020-16 – BGR 20 – Interpretation of the expression ‘substantially the whole’ 10 December 2013

LAPD-IntR-R-BGR-ARC-2020-15 – BGR 19 – Approval to end tax period on day other than last day of month 30 April 2013

LAPD-IntR-R-BGR-ARC-2020-13 – BGR 16 – Standard apportionment method 25 March 2013

LAPD-IntR-R-BGR-ARC-2020-12 – BGR 15 – Recipient-created tax invoices, credit and debit notes 22 March 2013

LAPD-IntR-R-BGR-ARC-2020-11a – BGR 14 (Issue 2) – VAT treatment supplies in short-term insurance industry 18 March 2016

LAPD-IntR-R-BGR-ARC-2020-11 – BGR 14 – VAT treatment of supplies in the short-term insurance industry 22 March 2013

LAPD-IntR-R-BGR-ARC-2020-10a – BGR 13 (Issue 2) – Calculation of VAT for certain betting transactions 26 March 2014

LAPD-IntR-R-BGR-ARC-2020-10 – BGR 13 – Calculation of VAT for certain betting transactions 22 March 2013

LAPD-IntR-R-BGR-ARC-2020-09a – BGR 12 (Issue 2) – Input tax on acquisition of second-hand motor vehicles 25 February 2016

LAPD-IntR-R-BGR-ARC-2020-09 – BGR 12 – Input tax on acquisition of second-hand motor vehicles 22 March 2013

LAPD-IntR-R-BGR-ARC-2020-08a – BGR 11 (Issue 2) – Use of an exchange rate 23 February 2016

LAPD-IntR-R-BGR-ARC-2020-06a – BGR 9 (Issue 2) – Taxes on income and similar taxes for purposes of SA DTAs 19 February 2013

LAPD-IntR-R-BGR-ARC-2020-06 – BGR 9 – Taxes on income and similar taxes for purposes of SA DTAs 12 August 2011

LAPD-IntR-R-BGR-ARC-2020-05 – BGR 8 – Application of the principles enunciated by the Brummeria Case 11 April 2011

LAPD-IntR-R-BGR-ARC-2020-04a – BGR 7 (Issue 2) – Wear-and-tear or depreciation allowance 2 November 2012

LAPD-IntR-R-BGR-ARC-2020-04 – BGR 7 – Wear-and-tear or depreciaton allowance 11 April 2011

LAPD-IntR-R-BGR-ARC-2020-03 – BGR 6 – Discounts, rebates, incentives fast moving consumable goods industry 25 March 2011

LAPD-IntR-R-BGR-ARC-2020-02a – BGR 4 (Issue 2) – Apportionment methodology Category A and B Municipalities 25 March 2013

LAPD-IntR-R-BGR-ARC-2020-02 – BGR 4 – Apportionment methodology Category A Municipalities 21 January 2010

LAPD-IntR-R-BGR-ARC-2020-01 – BGR 3 – Transitional arrangements municipalities 4 December 2007

LAPD-INTR-R-BGR-2022-01 – BGR 60 Disqualification as a qualifying company under section12R(4)(b)

LAPD-IntR-R-BGR-2020-12 – BGR54 Unbinding of unlisted company – impact of non qualifying shareholders

LAPD-IntR-R-BGR-2020-11 – BGR53 Rules for the taxation of interest payable by SARS under Section 7E

LAPD-IntR-R-BGR-2020-10 – BGR52 Timeframe for the export of goods by vendors and qualifying purchasers affected by COVID 19

LAPD-IntR-R-BGR-2019-03 – BGR51 Cancellation of registration of a foreign electronic services supplier

LAPD-IntR-R-BGR-2019-02 – BGR50 No-value provision in respect of the rendering of transport services by any employer

LAPD-IntR-R-BGR-2019-01 – BGR49 The supply and importation of sanitary towels (pads)

LAPD-IntR-R-BGR-2018-02 – BGR48 Temporary letting of dwellings by developers and the expiry of section 18B

LAPD-IntR-R-BGR-2018-01 – BGR47 Meaning of month for employers remunerating employees on a weekly our fortnightly basis

LAPD-IntR-R-BGR-2017-09 – BGR46 Supply of brown bread

LAPD-IntR-R-BGR-2017-08 – BGR45 Supply of potatoes

LAPD-IntR-R-BGR-2017-07 – BGR44 Meaning of 160 hours for purposes of section 4(1)(b)

LAPD-IntR-R-BGR-2017-06 – BGR43 Deduction of input in respect of second hand gold

LAPD-IntR-R-BGR-2017-05 – BGR42 No value provision in respect of transport services

LAPD-IntR-R-BGR-2017-04 – BGR41 VAT treatment of non-executive directors

LAPD-IntR-R-BGR-2017-03 – BGR40 Remuneration paid to non-executive directors

LAPD-IntR-R-BGR-2017-02 – BGR39 VAT treatment of municipal affected by changes to municipal boundaries

LAPD-IntR-R-BGR-2017-01 – BGR38 The VAT treatment of the supply and importation of vegetables and fruit

LAPD-IntR-R-BGR-2016-08 – BGR37 Zero-rating of international travel insurance

LAPD-IntR-R-BGR-2016-07 – BGR36 Circumstances prescribed by the Commissioner for the application of section 16(2)(g)

LAPD-IntR-R-BGR-2016-06 – BGR35 VAT treatment of the supply and importation of frozen potato products

LAPD-IntR-R-BGR-2016-05 – BGR34 Management of superannuation schemes – long-term insurers

LAPD-IntR-R-BGR-2016-04 – BGR33 The VAT treatment of the supply or importation of vegetable oil

LAPD-IntR-R-BGR-2016-03 – BGR32 VAT treatment of specific supplies in the short tem reinsurance industry

LAPD-IntR-R-BGR-2016-02 – BGR31 Interest on late payment of benefits

LAPD-IntR-R-BGR-2016-01 – BGR30 Allocation of direct and indirect expenses within and between an insurer’s funds

LAPD-IntR-R-BGR-2015-04 – BGR29 Unbundling Transactions Meaning End of Day after Distribution

LAPD-IntR-R-BGR-2015-02 – BGR27 The application of VAT sections 20(7) and 21(5)

LAPD-IntR-R-BGR-2015-01 – BGR26 VAT treatment of supply and importation of herbs

LAPD-IntR-R-BGR-2014-05 – BGR25 Exemption Foreign Pensions

LAPD-IntR-R-BGR-2014-04 – BGR24 Section 18A Receipt for Purposes of Deduction as in Section 37C

LAPD-IntR-R-BGR-2014-03 – BGR23 Travel Allowance Fuel Cost to Employee with Petrol or Garage Card

LAPD-IntR-R-BGR-2014-02 – BGR22 Subsistence Allowance Amounts deemed expended for business

LAPD-IntR-R-BGR-2014-01 – BGR21 Addresses on Tax Invoice Credit and Debit Notes

LAPD-IntR-R-BGR-2013-09 – BGR20 Interpretation of expression substantially the whole

LAPD-IntR-R-BGR-2013-08 – BGR19 Approval to end a tax period on a day other than the last day of a month

LAPD-IntR-R-BGR-2013-07 – BGR18 ZeroRating Various Types of Dates

LAPD-IntR-R-BGR-2013-06 – BGR17 Cancellation Registration Separate Enterprises Branches and Divisions

LAPD-IntR-R-BGR-2013-04 – BGR15 Recipient Created Tax Invoices Credit and Debit Notes

LAPD-IntR-R-BGR-2013-02 – BGR13 VAT Calculation Betting Transactions

LAPD-IntR-R-BGR-2013-01 – BGR12 Input Tax Acquisition NonTaxable Supply SecondHand Motor Vehicles

LAPD-IntR-R-BGR-2012-11 – Use Exchange Rate

LAPD-IntR-R-BGR-2012-09 – Taxes income RSA Tax Treaties

LAPD-IntR-R-BGR-2012-08 – Brummeria Case Principles

LAPD-IntR-R-BGR-2012-07 – Wear And Tear Depreciation Allowance

LAPD-IntR-R-BGR-2012-06 – Discounts Rebates Incentives Fast Moving Consumable Goods Industry

LAPD-IntR-R-BGR-2012-05 – Discounts Rebates Incentives Motor Industry

LAPD-IntR-R-BGR-2012-04 – BGR04 Apportionment Methodology to be applied by a Municipality

LAPD-IntR-R-BGR-2012-04 – Apportionment Methodology to be applied by a Municipality

LAPD-IntR-R-BGR-2012-03 – Transitional Arrangements Municipalities

LAPD-IntR-R-BGR-2012-02 – General Written Rulings Decisions

LAPD-IntR-R-BGR-2012-01 – VAT Rulings

INTR-R-BGR-2021-04 – BGR 59 Calculation of VAT for table games of chance

INTR-R-BGR-2021-03 – BGR 58 Purchase of different types of annuities at retirement

INTR-R-BGR-2021-02 – BGR 57 Whether the term “consideration” includes an amount of transfer duty

IntR-R-BGR-2021-01 – BGR56 Application for a decision under section 72

IntR-R-BGR-2020-13 – BGR55 Sale of dwellings by fixed property developers following a change in use adjustment under s 18

BPR Rulings

LP-IntR-R-BPR-354 – Cash grants to employee incentive trust to qualifying employees

Legal-R-BPR-389 – Bursaries awarded by a resident company

Legal-R-BPR-388 – Application of the de-grouping rule following previous intra-group transactions under section 45

Legal-R-BPR-387 – Attribution of nett income to a public benefit organisation

Legal-R-BPR-386 – Share disposal between two employee share incentive trusts

Legal-R-BPR-385 – Use of preference share proceeds to fund employee share ownership plan

Legal-R-BPR-384 – Cession to special trust of the beneficiary’s loan account

Legal-R-BPR-383 – Transfer of profits for group tax purposes between controlled foreign companies

Legal-R-BPR-382 – Rebate in respect of foreign taxes

Legal-R-BPR-381 – Beneficial ownership in respect of back-to-back share transfers

Legal-R-BPR-380 – Transfer of shares in resident company to non-resident holding company

Legal-R-BPR-379 – Qualifying purpose

Legal-R-BPR-378 – Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests

Legal-R-BPR-2022-08 – BPR 378 Transfer of listed financial instruments to collected investment schemes in exchange for participatory interests

Legal-R-BPR-2022-07 – BPR 377 Withholding of dividends tax at a reduced rate

Legal-R-BPR-2022-06 – BPR 376 Corporate restructuring

Legal-R-BPR-2022-05 – BPR 375 Unbundling of shares in a CFC

Legal-R-BPR-085 – Taxation Aspects Income Non Residents Employment South Africa

Legal-IntR-R-BPR-403 – Taxation of covered persons in respect of equity linked notes

Legal-IntR-R-BPR-402 – Transfer of long-term insurance business to a local branch of a foreign reinsurer

Legal-IntR-R-BPR-401 – Leasehold improvement allowance

Legal-IntR-R-BPR-400 – Donations tax implications on the issue of shares at nominal value to enhance BBBEE credentials

Legal-IntR-R-BPR-399 – Asset-for-share transaction and replacement asset

Legal-IntR-R-BPR-398 – Disposal of shares pursuant to a property development arrangement

Legal-IntR-R-BPR-397 – Income tax and securities transfer tax consequences resulting from an amalgamation transaction

Legal-IntR-R-BPR-396 – Settlement of shareholder’s loans

Legal-IntR-R-BPR-395 – Termination of a venture capital company

Legal-IntR-R-BPR-389 – Bursaries awarded by a resident company

Legal-IntR-R-BPR 394 – Instalment sale agreements and their sale to a non resident

Legal-IntR-R-BPR 393 – Income tax consequences resulting from consecutive asset-for-share transactions

Legal-IntR-R-BPR 392 – Sale of shares in a controlled foreign company (CFC)

Legal-IntR-R-BPR 391 – Tax consequences of the termination of an en commandite partnership

Legal-IntR-R-BPR 390 – Disposal in anticipation of liquidation

LAPD-IR-R-BPR-2022-04 – BPR 374 Determination of group of companies

LAPD-IR-R-BPR-2022-03 – BPR 373 STT treatment of the proposed transfer of listed shares to the applicant in order to hedge its exposure

LAPD-IR-R-BPR-2022-02 – BPR 372 Withholding tax on foreign royalties

LAPD-IR-R-BPR-2022-01 – BPR 371 Public Benefit Activities Carried on for the Benefit of the General Public

LAPD-IntR-R-BPR-2020-09 – BPR 345 Asset share transactions by an unbundling transaction and a sale of shares to third party

LAPD-IntR-R-BPR-2020-08 – BPR 344 Transfer of listed financial instruments to collective investment

LAPD-IntR-R-BPR-2020-07 – BPR 343 Donations tax implications of subscribing for shares at a discount

LAPD-IntR-R-BPR-2020-06 – BPR 342 Donation by a resident to a foreign trust of property received from another foreign trust

LAPD-IntR-R-BPR-2020-05 – BPR 341 Distribution of a bank account as dividend in specie

LAPD-IntR-R-BPR-2020-04 – BPR 340 Share buy-back at nominal value

LAPD-IntR-R-BPR-2020-03 – BPR 339 Transfer of listed shares to collective investment scheme

LAPD-IntR-R-BPR-2020-02 – BPR 338 Donations of money made to a public benefit organisation at a fundraising event

LAPD-IntR-R-BPR-2020-01 – BPR 337 Amalgamation transactions involving the assumption of liabilities only

LAPD-IntR-R-BPR-2019-22 – BPR 336 Liquidation distribution

LAPD-IntR-R-BPR-2019-21 – BPR 335 STT exemption for foreign governments

LAPD-IntR-R-BPR-2019-20 – BPR 334 Waiver of loan claims by the settlor of a trust

LAPD-IntR-R-BPR-2019-19 – BPR 333 Venture capital company investment in farming operations

LAPD-IntR-R-BPR-2019-18 – BPR 332 Unbundling and subsequent issue of listed shares by non-resident subsidiary

LAPD-IntR-R-BPR-2019-17 – BPR 331 De-grouping charge

LAPD-IntR-R-BPR-2019-16 – BPR 330 Distributions of dividends from a trust to beneficiaries on termination of employment

LAPD-IntR-R-BPR-2019-15 – BPR 329 Tax consequences of intra-group restructuring and subsequent sale of assets to third party

LAPD-IntR-R-BPR-2019-14 – BPR 328 Consecutive asset-for-share transactions

LAPD-IntR-R-BPR-2019-13 – BPR 327 Tax implications of a group restructuring

LAPD-IntR-R-BPR-2019-12 – BPR 326 Group restructuring transactions in a foreign jurisdiction

LAPD-IntR-R-BPR-2019-11 – BPR 325 Liquidation distribution and amalgamation transaction between non-resident companies

LAPD-IntR-R-BPR-2019-10 – BPR 324 Disposal and acquisition of shares by a public benefit organisation

LAPD-IntR-R-BPR-2019-09 – BPR 323 Debt reduction by means of set off

LAPD-IntR-R-BPR-2019-08 – BPR 322 Equity linked note

LAPD-IntR-R-BPR-2019-07 – BPR 321 Surplus retirement fund assets

LAPD-IntR-R-BPR-2019-06 – BPR 320 Conversion of association to private company

LAPD-IntR-R-BPR-2019-05 – BPR 319 Tax implications of group restructuring transactions

LAPD-IntR-R-BPR-2019-04 – BPR 318 Corporatisation of a collective investment scheme in property

LAPD-IntR-R-BPR-2019-03 – BPR 317 Disposal of Business by way of Asset-for-Share transaction

LAPD-IntR-R-BPR-2019-02 – BPR 316 Amalgation of companies in terms of Business Rescue Plan

LAPD-IntR-R-BPR-2019-01 – BPR 315 Future Expenditure

LAPD-IntR-R-BPR-2018-27 – BPR 314 Venture capital company – investment in hotel development

LAPD-IntR-R-BPR-2018-26 – BPR 313 Foreign share buyback

LAPD-IntR-R-BPR-2018-25 – BPR 312 Tax implications of the variation of employment contracts

LAPD-IntR-R-BPR-2018-24 – BPR 311 Photovoltaic solar energy plants

LAPD-IntR-R-BPR-2018-23 – BPR 310 Customer loyalty programme

LAPD-IntR-R-BPR-2018-22 – BPR 309 Disposal of an asset by a public benefit organisation

LAPD-IntR-R-BPR-2018-21 – BPR 308 Assumption of contingent liabilities and the cession of a right of recovery

LAPD-IntR-R-BPR-2018-20 – BPR 307 Relief from double taxation of interest

LAPD-IntR-R-BPR-2018-19 – BPR 306 Donation to a special trust

LAPD-IntR-R-BPR-2018-18 – BPR 305 registration of units in the name of beneficial owners

LAPD-IntR-R-BPR-2018-17 – BPR 304 Debt reduction and subsequent liquidation of debtor

LAPD-IntR-R-BPR-2018-16 – BPR 303 Tax implications of a group restructuring transaction

LAPD-IntR-R-BPR-2018-15 – BPR 302 Corporate restructuring and unbundling of listed shares

LAPD-IntR-R-BPR-2018-14 – BPR 301 Taxation of dividends received by a borrower under a securities lending arrangement

LAPD-IntR-R-BPR-2018-13 – BPR 300 Intra-group transaction and coversation of debt to equity

LAPD-IntR-R-BPR-2018-12 – BPR 299 Dividend distribution

LAPD-IntR-R-BPR-2018-11 – BPR 298 Waiver of debt

LAPD-IntR-R-BPR-2018-10 – BPR 297 Amalgamation transaction involving conversion of share block companies

LAPD-IntR-R-BPR-2018-09 – BPR 296 Disposal by a German Limited partnership of its assets to its sole member

LAPD-IntR-R-BPR-2018-08 – BPR 295 Distribution in specie of a share

LAPD-IntR-R-BPR-2018-07 – BPR 294 Amalgamation transaction between non-resident companies

LAPD-IntR-R-BPR-2018-06 – BPR 293 Disposal of shares by a non resident individual

LAPD-IntR-R-BPR-2018-05 – BPR 292 Tax consequences of a debt restructuring

LAPD-IntR-R-BPR-2018-04 – BPR 291 Deemed expenditure on meals and incidentals

LAPD-IntR-R-BPR-2018-03 – BPR 290 Distribution of shares to employee share scheme participants

LAPD-IntR-R-BPR-2018-02 – BPR 289 Base cost of loan claim and tax implications of acquisition transaction

LAPD-IntR-R-BPR-2018-01 – BPR 288 Consecutive asset for share transactions within 18 months

LAPD-IntR-R-BPR-2017-31 – BPR 287 Disposal of vacant land in exchange for shares

LAPD-IntR-R-BPR-2017-30 – BPR 286 Settling in allowance

LAPD-IntR-R-BPR-2017-29 – BPR 285 Initial fee paid to a franchisor

LAPD-IntR-R-BPR-2017-28 – BPR 284 Debentures tracking the value of a reference asset

LAPD-IntR-R-BPR-2017-27 – BPR 283 Intra-group disposal of capital asset

LAPD-IntR-R-BPR-2017-27 – BPR 283 Intra Group discposal of capital asset

LAPD-IntR-R-BPR-2017-26 – BPR 282 Deductibility of socio economic and enterprise development expenditure

LAPD-IntR-R-BPR-2017-25 – BPR 281 Disposal of a portion of land owned by a recreational club

LAPD-IntR-R-BPR-2017-24 – BPR 280 Debt reduction capital losses and corporate rules

LAPD-IntR-R-BPR-2017-23 – BPR 279 Capital gain tax participation in relation to controlled foreign companies

LAPD-IntR-R-BPR-2017-22 – BPR 278 Application of section 24JB to equity Linked notes

LAPD-IntR-R-BPR-2017-21 – BPR 277 Consequences for employee share trust of an employee share incentive scheme

LAPD-IntR-R-BPR-2017-20 – BPR 276 Dividends tax and the most favoured nation clause in a tax treaty

LAPD-IntR-R-BPR-2017-19 – BPR 275 Security arrangements in respect of home loans

LAPD-IntR-R-BPR-2017-18 – BPR 274 Venture Capital Company Investing in a company providing plants for solar electricity

LAPD-IntR-R-BPR-2017-17 – BPR 273 Waiver of a contractual right

LAPD-IntR-R-BPR-2017-16 – BPR 272 Deduction of expenditure incurred to acquire land development rights

LAPD-IntR-R-BPR-2017-15 – BPR 271 Acquisition of leased propery by the lessee pursuant to a liquidation distribution

LAPD-IntR-R-BPR-2017-14 – BPR 270 restructuring of propert portfolio under corporare rules

LAPD-IntR-R-BPR-2017-13 – BPR 269 IncomeTax consequences of a share buy-back

LAPD-IntR-R-BPR-2017-12 – BPR 268 Corrective Payments

LAPD-IntR-R-BPR-2017-11 – BPR 267 Dividends tax and the most favoured nation clause in a tax treaty

LAPD-IntR-R-BPR-2017-10 – BPR 266 Acquisition of a business in exchange for the assumption of liabilities

LAPD-IntR-R-BPR-2017-09 – BPR 265 Amalgation transaction

LAPD-IntR-R-BPR-2017-08 – BPR 264 Venture capital company shares

LAPD-IntR-R-BPR-2017-07 – BPR 263 Hybrid interest

LAPD-IntR-R-BPR-2017-06 – BPR 262 employer provided transport service

LAPD-IntR-R-BPR-2017-05 – BPR 261 repurchase of restricted equity instruments

LAPD-IntR-R-BPR-2017-04 – BPR 260 Interest on loans used to acquire shares

LAPD-IntR-R-BPR-2017-03 – BPR 259 Capital gains tax implications for an employee share trust

LAPD-IntR-R-BPR-2017-02 – BPR 258 Corporate Group Restructuring

LAPD-IntR-R-BPR-2017-01 – BPR 257 Islamic financing arrangement

LAPD-IntR-R-BPR-2016-41 – BPR 256 Mining Rehabilitation

LAPD-IntR-R-BPR-2016-40 – BPR 255 Debt reduction by means of set off

LAPD-IntR-R-BPR-2016-39 – BPR 254 Consequences of cross border and domestic asset for share transactions

LAPD-IntR-R-BPR-2016-38 – BPR 253 Donations Tax consequences of a transaction to introduce BEE shareholder into a group

LAPD-IntR-R-BPR-2016-37 – BPR 252 Donations tax and capital gains tax consequences of the part waiver of a loan

LAPD-IntR-R-BPR-2016-36 – BPR 251 Cancellation of reinsurance agreement

LAPD-IntR-R-BPR-2016-35 – BPR 250 Risk Policies

LAPD-IntR-R-BPR-2016-34 – BPR 249 Corporate group restructuring involving multiple transactions

LAPD-IntR-R-BPR-2016-33 – BPR 248 Deduction of interest on asset backed notes

LAPD-IntR-R-BPR-2016-32 – BPR 247 Employer contributions to foreign social and pension funds

LAPD-IntR-R-BPR-2016-31 – BPR 246 Debt reduction and capitalisation

LAPD-IntR-R-BPR-2016-30 – BPR 245 Time of accrual of short-term insurance premiums and time of supply of security provided

LAPD-IntR-R-BPR-2016-29 – BPR244 Disposal of an undivided interest in immovable property by way of an amalgamation transact

LAPD-IntR-R-BPR-2016-28 – BPR 243 Termination of a subcontracting agreement

LAPD-IntR-R-BPR-2016-27 – BPR242 Venture capital company investment in qualifying companies

LAPD-IntR-R-BPR-2016-26 – BPR241 Award received for a Black Economic Empowerment Training Initiative

LAPD-IntR-R-BPR-2016-25 – BPR240 Taxation of parties to share index linked notes

LAPD-IntR-R-BPR-2016-24 – BPR239 Cash Contributions made to a special purpose vehicle

LAPD-IntR-R-BPR-2016-23 – BPR238 Taxation of receipts by or accruals to a programme of activities

LAPD-IntR-R-BPR-2016-22 – BPR237 Reinstatement of a deregistered company to transfer immovable properties

LAPD-IntR-R-BPR-2016-21 – BPR236 Set-off of a loan account arising from an intra-group transaction to acquire equity shares

LAPD-IntR-R-BPR-2016-20 – BPR235 Income tax consequences for parties to an unbundling transaction

LAPD-IntR-R-BPR-2016-19 – BPR 234 Asset-for-share and unbundling transactions not regulated by sections 42 and 46

LAPD-IntR-R-BPR-2016-18 – BPR233 Transfer of a part of a business to a fellow subsidiary

LAPD-IntR-R-BPR-2016-17 – BPR232 Equity shares to be issued by resultant company as part of an amalgamation transaction


LAPD-IntR-R-BPR-2016-15 – BPR230 Disposal of an asset in terms of an asset-for-share transaction within 18 months

LAPD-IntR-R-BPR-2016-14 – BPR229 employer provided accommodation to employees

LAPD-IntR-R-BPR-2016-13 – BPR228 investment of preference share funding in a newly established business

LAPD-IntR-R-BPR-2016-12 – BPR227 Share subscription transaction follwed by two share repurchase transactions

LAPD-IntR-R-BPR-2016-11 – BPR226 Transfer of the long-term insurance business partly to a third party and partly intra-group

LAPD-IntR-R-BPR-2016-10 – BPR225 Hybrid debt instruments

LAPD-IntR-R-BPR-2016-09 – BPR224 Nonresident source of income from the operation of ships

LAPD-IntR-R-BPR-2016-08 – BPR223 Headquarter companies acquisitions of shares and loans

LAPD-IntR-R-BPR-2016-07 – BPR222 Foreign partnership rebate in respect of foreign taxes on income

LAPD-IntR-R-BPR-2016-06 – BPR221 Deductability of the cost of assets to be acquired to construct roads

LAPD-IntR-R-BPR-2016-05 – BPR220 Contribution by a mining company to a trust pursuant to share incentive scheme

LAPD-IntR-R-BPR-2016-04 – BPR219 Corporatisation of a collective investment scheme in property and an amalgamation

LAPD-IntR-R-BPR-2016-03 – BPR218 Qualifying distributions to be made by a REIT

LAPD-IntR-R-BPR-2016-02 – BPR217 Estate duty implications for non-resident individual investors

LAPD-IntR-R-BPR-2016-01 – BPR216 Tax consequences of the issuing of Tier 1 capital

LAPD-IntR-R-BPR-2015-30 – BPR215 Source and Nature of Satellite capacity fees

LAPD-IntR-R-BPR-2015-29 – BPR214 Third parties backed shares

LAPD-IntR-R-BPR-2015-28 – BPR213 repayment of intercompany loans from proceeds of a new share

LAPD-IntR-R-BPR-2015-27 – BPR212 Tax Consequences for the issuer of listed credit linked notes

LAPD-IntR-R-BPR-2015-26 – BPR211Transfer of exchange items using corporate rules

LAPD-IntR-R-BPR-2015-25 – BPR210 Liquidation distribution followed by an amalgamation transaction

LAPD-IntR-R-BPR-2015-24 – BPR209 Distribution of dividends to employees through a discretionary trust

LAPD-IntR-R-BPR-2015-23 – BPR208 Repayment of Shareholders loan from proceeds of a new share issue

LAPD-IntR-R-BPR-2015-22 – BPR207 Merger of two controlled foreign companies CFCs

LAPD-IntR-R-BPR-2015-21 – BPR206 Disposal by a share block company of its sectional title units to its share block holders

LAPD-IntR-R-BPR-2015-20 – BPR205 Definition of Controlled group company and equity share

LAPD-IntR-R-BPR-2015-19 – BPR204 Definition Disposal Asset for Share Amalgamation Qualifying Distribution REIT

LAPD-IntR-R-BPR-2015-18 – BPR203 Renunciation of a Usufruct over Shares

LAPD-IntR-R-BPR-2015-17 – BPR202 Application s13quin subsequent to IntraGroup transaction under s45

LAPD-IntR-R-BPR-2015-16 – BPR201 Issue of Capitalisation Shares

LAPD-IntR-R-BPR-2015-15 – BPR200 Source of Income of Commission payable to NonResident Junket Agents

LAPD-IntR-R-BPR-2015-14 – BPR199 Exemption from income tax of dvidends received from restricted equity instruments

LAPD-IntR-R-BPR-2015-13 – BPR198 Distribution of a debit loan account in anticipation of deregistration of a company

LAPD-IntR-R-BPR-2015-12 – BPR197 Exemption from Donations Tax and Net Value of Estate

LAPD-IntR-R-BPR-2015-11 – BPR196 Employees Tax Monthly Pension Benefits iro Foreign Services Rendered

LAPD-IntR-R-BPR-2015-10 – BPR195 STT Exemption where election was made that s42 will not apply

LAPD-IntR-R-BPR-2015-09 – BPR194 Disposal of Shares through Share BuyBack and Donation

LAPD-IntR-R-BPR-2015-08 – BPR193 Debt Reduction through SetOff

LAPD-IntR-R-BPR-2015-07 – BPR192 Cross Border Interest Free Loan Withholding Tax on Interest

LAPD-IntR-R-BPR-2015-06 – BPR191 Refinancing of debt through preference share funding

LAPD-IntR-R-BPR-2015-05 – BPR190 Notional Funding Arrangement Issue and Potential Repurchase Ordinary Shares

LAPD-IntR-R-BPR-2015-04 – BPR189 Acquisition of shares subject to suspensive conditions

LAPD-IntR-R-BPR-2015-03 – BPR188 Conversion of a PBO to a ForProfit Company

LAPD-IntR-R-BPR-2015-02 – BPR187 Waiver of IntraGroup Loan that funded Acquisition of Mining Operation

LAPD-IntR-R-BPR-2015-01 – BPR186 Asset-for-share between resident private company and CIS in securities

LAPD-IntR-R-BPR-2014-28 – BPR185 Corporate Rules Disposal of Assets and Liabilities Part of Group Restructure

LAPD-IntR-R-BPR-2014-27 – BPR184 Asset-for-Share Transaction

LAPD-IntR-R-BPR-2014-26 – BPR183 Employee Housing Scheme

LAPD-IntR-R-BPR-2014-25 – BPR182 Waiver of debt that funded mining capital expenditure

LAPD-IntR-R-BPR-2014-24 – BPR181 Withholding tax on interest re foreign government

LAPD-IntR-R-BPR-2014-23 – BPR180 Improvements on land not owned by taxpayer

LAPD-IntR-R-BPR-2014-22 – BPR179 Single premium life insurance policy issued by an off-shore insurer

LAPD-IntR-R-BPR-2014-21 – BPR178 International corporate restructuring

LAPD-IntR-R-BPR-2014-20 – BPR177 Improvements on land by sub lessee under a sub lease

LAPD-IntR-R-BPR-2014-19 – BPR176 Financial Instruments Listed Company Application Words Investment Purposes

LAPD-IntR-R-BPR-2014-18 – BPR175 Debt purchase transactions

LAPD-IntR-R-BPR-2014-17 – BPR174 Receipts of incentive trust and vesting of shares in qualifying employees

LAPD-IntR-R-BPR-2014-16 – BPR173 Repayment Shareholder Loan from Proceeds of New Issue of Ordinary Shares

LAPD-IntR-R-BPR-2014-15 – BPR172 Plant used in Production of Renewable Energy


LAPD-IntR-R-BPR-2014-13 – BPR170 Definition of Unrestricted Equity Instrument

LAPD-IntR-R-BPR-2014-12 – BPR169 Commercial Building Allowance

LAPD-IntR-R-BPR-2014-11 – BPR168 Corporate Rule Disposal of Assets within 18 months

LAPD-IntR-R-BPR-2014-10 – BPR167 Debentures Tracking Value of Reference Asset

LAPD-IntR-R-BPR-2014-09 – BPR166 Change of Place of Incorporation Domicile of Controlled Foreign Company

LAPD-IntR-R-BPR-2014-08 – BPR165 Letting of accommodation where the provision of meals is outsourced

LAPD-IntR-R-BPR-2014-07 – BPR164 Buyback Shares at Purchase Price in Excess of Market Value

LAPD-IntR-R-BPR-2014-06 – BPR163 Interest on Replacement Loans and Proceeds arising from Share Repurchase

LAPD-IntR-R-BPR-2014-05 – BPR162 Sale of an oil and gas right

LAPD-IntR-R-BPR-2014-04 – BPR161 Employee Share Ownership Plan

LAPD-IntR-R-BPR-2014-03 – BPR160 Incentive Payments

LAPD-IntR-R-BPR-2014-02 – BPR159 Asset for share and amalgamation transactions

LAPD-IntR-R-BPR-2014-01 – BPR158 Transport services provided by an employer for employees

LAPD-IntR-R-BPR-2013-17 – BPR157 Receipt of Foreign Assets Subsequent Donation to NonResident Trust

LAPD-IntR-R-BPR-2013-16 – BPR156 Pension benefits accruing to nonresident from resident pension fund

LAPD-IntR-R-BPR-2013-15 – BPR155 Incentive for Oil and Gas Production

LAPD-IntR-R-BPR-2013-14 – BPR154 Corporate Rules Acquisition Debtors Book

LAPD-IntR-R-BPR-2013-13 – BPR153 Residency Status Non Resident Applying for Temporary Permit

LAPD-IntR-R-BPR-2013-12 – BPR152 CGT Cancellation and Extinguishment of Right to Interest

LAPD-IntR-R-BPR-2013-11 – BPR151 Renunciation of an inheritance

LAPD-IntR-R-BPR-2013-10 – BPR150 Tax Treatment Relating To Credit Linked Deposit

LAPD-IntR-R-BPR-2013-09 – BPR149 Disposal Asset Equity Share Foreign Company

LAPD-IntR-R-BPR-2013-08 – BPR148 Dividends Tax Rate Permanent Establishment RSA

LAPD-IntR-R-BPR-2013-07 – BPR147 Consideration received for the surrender of a right to acquire shares

LAPD-IntR-R-BPR-2013-06 – BPR146 Mining tax Contract agreement

LAPD-IntR-R-BPR-2013-05 – BPR145 Allowances assets forming part of a sale and leaseback arrangement

LAPD-IntR-R-BPR-2013-04 – BPR144 Write off period of increase in cost or the value of assets

LAPD-IntR-R-BPR-2013-03 – BPR143 Preference shares constituting equity shares in relation to a headquarter company

LAPD-IntR-R-BPR-2013-02 – BPR142 Deduction of Interest Expenditure

LAPD-IntR-R-BPR-2013-01 – BPR141 Transfer of securities

LAPD-IntR-R-BPR-2012-99 – Transfer Beneficial Ownership South African Listed Shares Riskless Principal Transaction

LAPD-IntR-R-BPR-2012-98 – Capital Gain Loss Ceded Policies

LAPD-IntR-R-BPR-2012-97 – CGT Liability Assets Trust Vest Hands Vesting Beneficiaries

LAPD-IntR-R-BPR-2012-96 – Group Restructuring Transactions Possible Relief Measures

LAPD-IntR-R-BPR-2012-95 – Adequate Consideration Section 58

LAPD-IntR-R-BPR-2012-94 – Charges Incurred Acquisition Trading Stock

LAPD-IntR-R-BPR-2012-93 – Deductibility Environmental Expenditure Asset Share Transaction

LAPD-IntR-R-BPR-2012-92 – Possible Recoupment Rental Paid Subsequent Acquisition Leased Property

LAPD-IntR-R-BPR-2012-91 – Securities Lending Transaction

LAPD-IntR-R-BPR-2012-90 – Royalty Attributable Foreign Business Establishment Controlled Foreign Company

LAPD-IntR-R-BPR-2012-89 – Waiver Certain Rights Connected Shares

LAPD-IntR-R-BPR-2012-88 – Contributed Capital Foreign Limited Liability Cooperative

LAPD-IntR-R-BPR-2012-87 – CGT Consequences Restructuring Activities Involving Trusts

LAPD-IntR-R-BPR-2012-86 – Application Legislation Two Parties Mining Operations Unincorporated Joint Venture Agreement

LAPD-IntR-R-BPR-2012-84 – Group Companies Concept Section 45

LAPD-IntR-R-BPR-2012-83 – CGT Implications Conversion Company Amendment Incorporation Documentation

LAPD-IntR-R-BPR-2012-82 – Permanent Establishment Royalties

LAPD-IntR-R-BPR-2012-81 – Determination Value Taxable Benefit Residential Accommodation

LAPD-IntR-R-BPR-2012-80 – Donation Shares

LAPD-IntR-R-BPR-2012-79 – Land Owner Developer Residential Township Development Lease Agreements

LAPD-IntR-R-BPR-2012-78 – Income Tax Consequences Leasehold Improvements Both Lessor Lessee

LAPD-IntR-R-BPR-2012-77 – Transfer Compensation Award Granted Incapacitated Person Trust Administered Trustees

LAPD-IntR-R-BPR-2012-76 – Nature Income Hands Vested Beneficiary Trust


LAPD-IntR-R-BPR-2012-74 – Date Shares Vest Taxpayer Related Interest Expense

LAPD-IntR-R-BPR-2012-73 – Extinction Inter Company Loans Result Voluntary Winding Up

LAPD-IntR-R-BPR-2012-72 – VAT Implications Qualified Goods Imported Processing Exportation End Products

LAPD-IntR-R-BPR-2012-71 – Improvements Leasehold Property

LAPD-IntR-R-BPR-2012-70 – CGT Implications Transfer Trust Funds Offshore Discretionary Trust

LAPD-IntR-R-BPR-2012-69 – VAT Implications Supply Services Mitigation Costs Time Supply

LAPD-IntR-R-BPR-2012-68 – Classification Extraction Clay Soil

LAPD-IntR-R-BPR-2012-67 – Foreign Business Establishment Sharing Employees Equipment Facilities Same Group

LAPD-IntR-R-BPR-2012-66 – Deductibility Interest Loans Group Companies Going Concerns Acquisition Shares Holding Company

LAPD-IntR-R-BPR-2012-65 – Determination Residency South African Income Tax Purposes Ordinarily Resident

LAPD-IntR-R-BPR-2012-64 – Employees Annuity Payments Long Term Insurance Company




LAPD-IntR-R-BPR-2012-60 – Short Sale Transactions Securities Lending Arrangements

LAPD-IntR-R-BPR-2012-59 – Corporate Rules Transfer Assets Sole Proprietor Companies Close Corporations

LAPD-IntR-R-BPR-2012-58 – Acquisition Shares Result Company Restructuring Interest Loan

LAPD-IntR-R-BPR-2012-57 – Interest Loan Business Company Going Concern Acquisition Shares

LAPD-IntR-R-BPR-2012-56 – Taxability Income CGT Vesting Beneficiaries

LAPD-IntR-R-BPR-2012-55 – Application Definition Dividend Redemption Participatory Interest Foreign Collective Investment

LAPD-IntR-R-BPR-2012-54 – Corporate Rules Amalgamation Transactions

LAPD-IntR-R-BPR-2012-53 – VAT Implications Construction Buildings Donations

LAPD-IntR-R-BPR-2012-52 – Repatriation Profits Foreign Dividends Foreign Subsidiary Resident Company

LAPD-IntR-R-BPR-2012-51 – Environmental Expenditure Allowances

LAPD-IntR-R-BPR-2012-50 – Cash Grants Employer to Share Incentive Scheme Trusts Deductibility

LAPD-IntR-R-BPR-2012-49 – Nature Proceeds Lease Property 99 Year Lease

LAPD-IntR-R-BPR-2012-48 – Deeming Place Foreign Business Establishment Envisaged Section 9D

LAPD-IntR-R-BPR-2012-47 – Agency Income Earned Controlled Foreign Company Excluded Net Income

LAPD-IntR-R-BPR-2012-46 – Accrual Unclaimed Retirement Fund Lump Sum Benefit

LAPD-IntR-R-BPR-2012-45 – Deductibility Conditional Interest Loan

LAPD-IntR-R-BPR-2012-44 – Foreign Business Establishment Exclusion

LAPD-IntR-R-BPR-2012-43 – Private Use Company Motor Vehicle

LAPD-IntR-R-BPR-2012-42 – Determination Qualification Film Owner Section 24F

LAPD-IntR-R-BPR-2012-41 – Impact De Grouping Provisions Same Company

LAPD-IntR-R-BPR-2012-40 – Liability Withhold Employees Tax Section 8C Gains Employee Share Option Scheme

LAPD-IntR-R-BPR-2012-39 – Consequences Unbundling Shares Distribution Foreign Jurisdictions

LAPD-IntR-R-BPR-2012-37 – Disposal Right Royalty Income Intra Group Transaction Debt Cancellation

LAPD-IntR-R-BPR-2012-36 – Applicability Tax Dispensation Specific Contract Mining Arrangement

LAPD-IntR-R-BPR-2012-35 – Definition Group Companies Connected Person

LAPD-IntR-R-BPR-2012-34 – Applicability Tax Dispensations Specific Contract Mining Arrangement

LAPD-IntR-R-BPR-2012-33 – Applicability Tax Dispensations Specific Contract Mining Agreement

LAPD-IntR-R-BPR-2012-32 – Payments Third Party Manufacturing Facility

LAPD-IntR-R-BPR-2012-31 – Sale Shares Collective Investment Scheme Proceeds Capital Revenue

LAPD-IntR-R-BPR-2012-30 – Distributions Collective Investment Scheme Reinvested

LAPD-IntR-R-BPR-2012-29 – Provision Free Meals Refreshments Employees

LAPD-IntR-R-BPR-2012-28 – Deduction Recurring Expenditure Hybrid Debt Instruments Proceeds Primary Share Capital

LAPD-IntR-R-BPR-2012-27 – Taxation Aspects Amalgamation Transaction

LAPD-IntR-R-BPR-2012-26 – Sale Land Lease Going Concern

LAPD-IntR-R-BPR-2012-25 – Replacement Debt Subsequent Transfer Assets For Share Transaction

LAPD-IntR-R-BPR-2012-24 – Share Relief Provision

LAPD-IntR-R-BPR-2012-23 – VAT Implications Residential Township Development

LAPD-IntR-R-BPR-2012-22 – Taxation Aspects Bonuses Penalties Employees Bonus Incentive Retention Scheme

LAPD-IntR-R-BPR-2012-21 – Date Restricted Equity Instruments Vest Liability Withhold Employees Tax

LAPD-IntR-R-BPR-2012-20 – Impact Transfer Share Premium Nature

LAPD-IntR-R-BPR-2012-19 – Receipt Cash payment Trust Disposal Vested Rights CGT

LAPD-IntR-R-BPR-2012-18 – Deduction Letting Commission Property Investment Company Property Management Company

LAPD-IntR-R-BPR-2012-17 – Supply Trophy Accommodation Services Foreign Resident

LAPD-IntR-R-BPR-2012-16 – Loans Subsidiary Company to Holding Company

LAPD-IntR-R-BPR-2012-15 – Supply Goods Services Vendors Same Person Acquisition Fixed Property Exemption Transfer Duty

LAPD-IntR-R-BPR-2012-140 – Unbundling Transaction

LAPD-IntR-R-BPR-2012-14 – Employees Tax Gains Sections 8A and 8C Retired Employees

LAPD-IntR-R-BPR-2012-139 – Disposal of Assets by a Recreational Club

LAPD-IntR-R-BPR-2012-138 – Subscription Shares Nominal Values Coupled Repurchase Agreement

LAPD-IntR-R-BPR-2012-137 – Sale Business Intragroup Transaction

LAPD-IntR-R-BPR-2012-136 – Taxation Subsistence Allowances Employees

LAPD-IntR-R-BPR-2012-135 – Improvements Effected Land Long Term Lease

LAPD-IntR-R-BPR-2012-134 – Exemption Foreign Dividend Deemed Received Resident

LAPD-IntR-R-BPR-2012-133 – Transfer Residence Company Natural Person

LAPD-IntR-R-BPR-2012-132 – Disposal Business Going Concern Trust Company Exchange Shares

LAPD-IntR-R-BPR-2012-131 – Vesting Date Restricted Equity Instrument

LAPD-IntR-R-BPR-2012-130 – Sale Mining Rights Base Cost Each Mining Right

LAPD-IntR-R-BPR-2012-13 – Section 8C Variation Share Options Schemes

LAPD-IntR-R-BPR-2012-129 – Beneficial Owner Dividends

LAPD-IntR-R-BPR-2012-128 – Disposal Equity Shares Foreign Company

LAPD-IntR-R-BPR-2012-127 – Relief Double Taxation Foreign Income

LAPD-IntR-R-BPR-2012-126 – Disposal Business Investment Shares Restructuring Distribution Shareholders

LAPD-IntR-R-BPR-2012-125 – Vesting Discretionary Trust Dividend Rights Beneficiary Trust

LAPD-IntR-R-BPR-2012-124 – Repayment Shareholders Loans Proceeds New Issue Redeemable Preference Shares

LAPD-IntR-R-BPR-2012-123 – Fibre Optic Cable Electronic Communications

LAPD-IntR-R-BPR-2012-122 – Transfer Business Company Going Concern Holding Company Amalgamation Merger Transaction

LAPD-IntR-R-BPR-2012-121 – Secondary Tax Companies Dividends Tax

LAPD-IntR-R-BPR-2012-120 – Interaction Section 45 Section 47J Transfer Interest Bearing Receivables Corporate Rules

LAPD-IntR-R-BPR-2012-12 – Determination Gross Income Livestock Auctioneer Agent

LAPD-IntR-R-BPR-2012-119 – Transfer Amounts Contributed Foreign Pension Fund South African Retirement Annuity Fund

LAPD-IntR-R-BPR-2012-118 – Witholding Dividends Tax

LAPD-IntR-R-BPR-2012-117 – Obligation Deduct Withhold Employees Tax Share Option

LAPD-IntR-R-BPR-2012-116 – Distribution Resident Beneficiary Trust Donation Another Non Resident Trust

LAPD-IntR-R-BPR-2012-115 – Incentive Rewards Paid Independent Sales Persons

LAPD-IntR-R-BPR-2012-114 – Loan Facilities Raised Foreign Permanent Establishment

LAPD-IntR-R-BPR-2012-113 – Expenditure Associated Broad Based Black Economic Empowered

LAPD-IntR-R-BPR-2012-112 – Interposing Cooperative South African Holding Company Foreign Subsidiaries

LAPD-IntR-R-BPR-2012-111 – Research Development Expenditure Paid Fellow Group Company Not Resident

LAPD-IntR-R-BPR-2012-110 – Toll Manufacturing Agreement Attribution Global Sales South African Manufactured Products

LAPD-IntR-R-BPR-2012-11 – Transfer Pre 1 March 1998 Amount Pension Fund Own Contribution

LAPD-IntR-R-BPR-2012-109 – Loan Granted Embedded Option

LAPD-IntR-R-BPR-2012-108 – Issue Redeemable Preference Shares Reserves Available Distribution

LAPD-IntR-R-BPR-2012-107 – Recoupment Lease Premium Rental Amouns Deductions Leased Property

LAPD-IntR-R-BPR-2012-106 – Application section 24C maintenance trust

LAPD-IntR-R-BPR-2012-105 – Resident Single Premium Whole Life Insurance Policy Offshore Insurer

LAPD-IntR-R-BPR-2012-104 – Intra Group Transfer Shares Result Restructuring

LAPD-IntR-R-BPR-2012-103 – Share Incentive Scheme

LAPD-IntR-R-BPR-2012-102 – Registation External company Identifying Permanent Establishment

LAPD-IntR-R-BPR-2012-101 – Securities Transfer Tax Asset Share Transaction

LAPD-IntR-R-BPR-2012-100 – Date Accrual Short Term Insurance Premiums Guarantee Policy Suretyship Master

LAPD-IntR-R-BPR-2012-10 – Applicability Mining Tax Dispensations Specific Contract

LAPD-IntR-R-BPR-2012-09 – Sale Administration Business

LAPD-IntR-R-BPR-2012-08 – Variable Payments Marketing Executive Application Section 23

LAPD-IntR-R-BPR-2012-07 – Service Fees Non Resident Labour Broker

LAPD-IntR-R-BPR-2012-06 – Application Section 24C Repair Maintenance Contract

LAPD-IntR-R-BPR-2012-05 – Dividend Income Trust Nature Beneficiaries Distribution Same Tax Year

LAPD-IntR-R-BPR-2012-04 – Definition Enterprise Exemption Goods Importation

LAPD-IntR-R-BPR-2012-03 – Method Determination Valuation Date Value Financial Instruments CGT

LAPD-IntR-R-BPR-2012-02 – Method Determination Interest Amount Collection Distressed Debtors Book

LAPD-IntR-R-BPR-2012-01 – Definition Enterprise Zero Rating Salvage Services Personal Subsistence

INTR-R-BPR-2021-14 – BPR 370 Registration of shares in the name of beneficial holder

INTR-R-BPR-2021-13 – BPR 369 Deductibility of interest incurred pursuant to liquidation of company

INTR-R-BPR-2021-12 – BPR 368 Payments made pursuant to an agreement relating to a permission to occupy

IntR-R-BPR-2021-10 – BPR 366 Distribution in specie of shares

IntR-R-BPR-2021-09 – BPR 365 Interpretation and application of the de-grouping provision in section 45(4)(b)

IntR-R-BPR-2021-08 – BPR 364 Extraordinary dividend followed by the dilution of shareholders’ interest

IntR-R-BPR-2021-07 – BPR 363 Value of a suppy of services

IntR-R-BPR-2021-06 – BPR 362 Transfer of assets between share incentive trusts

IntR-R-BPR-2021-05 – BPR 361 – Asset-for-share transaction followed by an unbundling transaction

IntR-R-BPR-2021-04 – BPR 360 Internal restructure followed by a disposal of shares to a BBBEE investor

IntR-R-BPR-2021-03 – BPR 359 Transfer of reinsurance business from a resident company to a local branch of a foreign company

IntR-R-BPR-2021-02 – BPR 358 Amalgamation of short and long-term insurers

IntR-R-BPR-2021-01 – BPR 357 Donations to a foreign trust of property situated outside the republic

IntR-R-BPR-2020-20 – BPR 356 Preference share – hybrid equity instrument and third-party backed share

IntR-R-BPR-2020-19 – BPR 355 Accrual of pension payments to a resident from a foreign pension fund

IntR-R-BPR-2020-17 – BPR 353 Linear adjustment of gross sales of unrefined mineral resource

IntR-R-BPR-2020-16 – BPR 352 Taxation of employees participating in an option programme

IntR-R-BPR-2020-15 – BPR 351 Waiver of an intra group loan to, and subsequent liquidation distribution by a subsidiary

IntR-R-BPR-2020-14 – BPR 350 Vesting of a capital gain in a trust beneficiary and deferral of its payment

IntR-R-BPR-2020-13 – BPR 349 Acquisition of equity shares in non-resident REIT

IntR-R-BPR-2020-12 – BPR 348 Income Tax consequences for a PBO lending funds to qualifying entrepreneurs

IntR-R-BPR-2020-11 – BPR 347 Temporary setting aside of a voluntary liquidation

IntR-R-BPR-2020-10 – BPR 346 Tax implications resulting from the elimination of intra-group loans

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