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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 041 | Impact of the de-grouping provisions where the transferror in the first intra-group transaction and the transferee in the second intra-group transaction are the same company |
| BPR 042 | Determination of who qualifies as a ‘film owner’ for purposes of section 24F The guidance contained in this ruling is affected by subsequent law changes |
| BPR 043 | Private use of a company motor vehicle |
| BPR 044 | Foreign business establishment exclusion |
| BPR 045 | Deductibility of conditional interest incurred in terms of a loan |
| BPR 046 | Accrual of an unclaimed retirement fund (lump sum) benefit |
| BPR 047 | Agency income earned by a controlled foreign company to be excluded from its net income |
| BPR 048 | Deeming a place of business to be a ‘foreign business establishment’ as envisaged in section 9D(1) The guidance contained in this ruling is affected by subsequent law changes |
| BPR 049 | Nature of proceeds received for the lease of property in terms of a 99 year lease The guidance contained in this ruling is affected by subsequent case law |
| BPR 050 | Cash grants made by an employer to share-incentive scheme trusts and their deductibility for tax purposes |
| BPR 051 | Environmental expenditure allowances |
| BPR 052 | Repatriation of profits in the form of foreign dividends paid by a foreign subsidiary to a resident company which was previously exempt from income tax The guidance contained in this ruling may be affected by subsequent law changes |
| BPR 053 | Value-added tax implications arising from the construction of buildings by an entity and the subsequent donation of such buildings to another entity |
| BPR 054 | Corporate rules – amalgamation transactions |
| BPR 055 | Application of the definition of ‘dividend’ to the redemption of a participatory interest by a foreign collective investment scheme |
| BPR 056 | Taxability of income and capital gains in the hands of vesting beneficiaries whether a resident or not (Income Tax Act, 1962) |
| BPR 057 | Interest incurred on a loan obtained to acquire the business of a company as a going concern through the acquisition of the shares of the company |
| BPR 058 | Acquisition of shares as a result of company restructuring and interest on a loan created in the restructuring process |
| BPR 059 | Corporate rules – Transfer of the assets of a businesses conducted by a sole proprietor to companies and close corporations |
| BPR 060 | Short sale transactions and securities lending arrangements |
