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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 081 | Determination of the value of the taxable benefit of residential accommodation |
| BPR 082 | Permanent establishment and royalties |
| BPR 083 | Capital gains tax implications on the conversion of a company through the amendment of its incorporation documentation |
| BPR 084 | The ‘group of companies’ concept for the purposes of section 45(4) |
| BPR 085 | Taxation aspects of income derived by non South African residents from employment in South Africa |
| BPR 086 | Application of relevant legislation where two parties conduct mining operations in terms of an unincorporated joint venture agreement |
| BPR 087 | Capital gains tax consequences arising from restructuring activities involving trusts |
| BPR 088 | Contributed capital of a foreign limited liability co-operative |
| BPR 089 | Waiver of certain rights connected to shares |
| BPR 090 | Royalty income attributable to a foreign business establishment of a controled foreign company |
| BPR 091 | Securities lending transaction |
| BPR 092 | Possible recoupment of rental paid on the subsequent acquisition of the leased property by the lessee |
| BPR 093 | Deductibility of environmental expenditure subsequently incurred in respect of asset that have been acquired in an asset-for-share transaction |
| BPR 094 | Charges incurred in relation to the acquisition of trading stock |
| BPR 095 | Adequate consideration as contemplated under section 58(1) |
| BPR 096 | Group restructuring transactions and possible relief measures |
| BPR 097 | Capital gains tax liability in relation to assets of a trust which vest in the hands of the vesting beneficiaries |
| BPR 098 | Capital gain or loss on ceded policies |
| BPR 099 | Transfer of beneficial ownership of South African listed shares under a ‘riskless principal’ transaction |
| BPR 100 | Date of accrual of short-term insurance premiums payable in terms of a guarantee policy, suretyship provided to the Master of the High Court and the time of supply of the guarantee policy |
