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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 |
---|---|
Employee Share Ownership Plan | |
Sale of an oil and gas right | |
BPR 163 | Interest on replacement loans and proceeds arising from a share repurchase |
BPR 164 | Buyback of shares at a purchase price in excess of their market value |
Letting of accommodation where the provision of meals is outsourced | |
Change of place of incorporation (domicile) of a controlled foreign company | |
Debentures tracking the value of a reference asset | |
BPR 168 | Corporate rule: Disposal of assets within 18 months of acquisition |
Commercial building allowance | |
Definition of unrestricted equity instrument | |
Amalgamation Transaction | |
Plant used in the production of renewable energy | |
Repayment of shareholder loan from proceeds of a new issue of ordinary shares | |
BPR 174 | Receipts of an incentive trust and vesting of shares in qualifying employees Some of the guidance contained in this ruling is affected by subsequent law changes. Refer to BPR 354. |
Debt purchase transactions | |
Financial instruments not issued by a “listed company” as defined; Application of the words “for investment purposes” | |
Improvements on land by sub-lessee under a sub-lease | |
International corporate restructuring | |
Single premium life insurance policy issued by an off-shore insurer | |
Improvements effected on land not owned by taxpayer |