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 121 | Secondary tax on companies or dividends tax |
| BPR 122 | Transfer of a business of a company as a going concern to its holding company as a result of an amalgamation or merger transaction |
| BPR 123 | Fibre optic cable to be used for electronic communications |
| BPR 124 | Repayment of shareholders’ loans from proceeds of a new issue of redeemable preference shares |
| BPR 125 | Vesting by discretionary trust of dividend rights to the beneficiary of the trust |
| BPR 126 | Disposal of a business and investment shares as a result of restructuring, and the distribution of certain shares to shareholders |
| BPR 127 | Relief from double taxation of foreign income |
| BPR 128 | Disposal of equity shares in a foreign company |
| BPR 129 | Beneficial owner of dividends |
| BPR 130 | Sale of mining rights and the respective base cost of each mining right |
| BPR 131 | Vesting date of a restricted equity instrument |
| BPR 132 | Disposal of a business as a going concern by a trust to a company in exchange for shares in the company |
| BPR 133 | Transfer of a residence out of a company to a natural person |
| BPR 134 | Exemption under section 10B(2)(a) in relation to a foreign dividend that is deemed to be received by a person who is a resident |
| BPR 135 | Improvements effected on land in terms of a long term lease |
| BPR 136 | Taxation of subsistence allowances paid to employees |
| BPR 137 | Sale of a business in terms of an intra-group transaction |
| BPR 138 | Subscription for shares at nominal values coupled to a repurchase agreement at the same nominal values |
| BPR 139 | Disposal of assets by a recreational club |
| BPR 140 | Unbundling transactions |