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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 021 | Date upon which restricted equity instruments vest and the date on which the liability to withhold employees’ tax arises |
| BPR 022 | Taxation aspects of bonuses and penalties payable in terms of an employees’ bonus incentive and retention scheme The guidance contained in this ruling is affected by subsequent law changes |
| BPR 023 | Value-added tax implications to the parties relating to the establishment of a residential township development |
| BPR 024 | Share for share relief provision The guidance contained in this ruling is affected by subsequent law changes |
| BPR 025 | The replacement of debt and the subsequent transfer thereof together with the assets in an asset-for-share-transaction |
| BPR 026 | Sale of land subject to a lease with assignment of that lease – going concern |
| BPR 027 | Taxation aspects of an amalgamation transaction The guidance contained in this ruling is affected by subsequent law changes |
| BPR 028 | Deduction of recurring expenditure incurred in terms of hybrid-debt instruments where the proceeds of such instruments rank as primary share capital for a bank |
| BPR 029 | Provision of free meals and refreshments to employees |
| BPR 030 | Distributions made by a collective investment scheme which are reinvested with the scheme |
| BPR 031 | Sale of shares held in a collective investment scheme – whether the proceeds are capital or revenue in nature |
| BPR 032 | Payments made to a third party for making available its manufacturing facility |
| BPR 033 | Applicability of tax dispensations contained in the Act with regard to a specific contract mining agreement |
| BPR 034 | Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement |
| BPR 035 | Definition of group of companies and connected person The guidance contained in this ruling is affected by subsequent law changes |
| BPR 036 | Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement |
| BPR 037 | Disposal of the right to receive royalty income – an intra-group transaction or a debt cancellation |
| BPR 038 | Tax implications for a resident relating to a single premium whole-of-life insurance policy issued by offshore insurers Ruling rendered void: 22 June 2010 |
| BPR 039 | Consequences of an unbundling transaction regarding the number of shares to be distributed and the distribution of shares to shareholders who are resident in certain foreign jurisdictions The guidance contained in this ruling is affected by subsequent law changes |
| BPR 040 | Liability to withhold employees’ tax in respect of section 8C gains realised by participants in an employee share option scheme |
