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 | ||
|---|---|---|---|
| Deductibility of the cost of assets to be acquired to construct roads | |||
| BPR 222 | Foreign partnership – Rebate in respect of foreign taxes on income | ||
| BPR 223 | Headquarter companies: Acquisitions of shares and loans | ||
| BPR 224 | Non-resident – Source of income from the operation of ships | ||
| BPR 225 | Hybrid debt instruments | ||
| BPR 226 | Transfer of the long-term insurance business, partly to a third party and partly intra-group | ||
| BPR 227 | Share subscription transaction followed by two share repurchase transactions | ||
| BPR 228 | Whether an investment of preference share funding in a newly established business is for a “qualifying purpose” | ||
| BPR 229 | Employer provided accommodation to employees | ||
| BPR 230 | Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an intra-group transaction | ||
| BPR 231 |
Corporate restructuring by way of asset-for-share and amalgamation transactions The principle confirmed in this ruling in respect of transaction 1 and 2 has been reviewed. This ruling should not be relied upon by anyone other than the Applicant(s) or class members to whom it was issued. |
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| BPR 232 | Equity shares to be issued by resultant company as part of an amalgamation transaction | ||
| BPR 233 | Transfer of a part of a business to a fellow subsidiary | ||
| BPR 234 | Asset-for-share and unbundling transactions not regulated by sections 42 and 46 | ||
| BPR 235 | Income tax consequences for parties to an unbundling transaction | ||
| BPR 236 |
Set-off of a loan account arising from an intra-group transaction to acquire equity shares
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| BPR 237 | Reinstatement of a deregistered company to transfer immovable properties | ||
| BPR 238 | Taxation of receipts by or accruals to a programme of activities of a clean development mechanism project | ||
| BPR 239 | Cash contributions made to a special purpose vehicle established to provide housing to mine workers | ||
| BPR 240 | Taxation of parties to share index linked notes |
