BPR61 (ITA) – Application of the definitions of ‘company’ and ‘controlled foreign company’ with regard to a foreign limited partnership (“Company” definition, section 9D, section 10) Posted on January 23, 2019 by admin_kmos
BPR62 (ITA) – Settlement of loan by offshore holdco in favour of SA sub. without requiring quid pro quo (8(4)(m), 20(1)(a)(ii), 54, 64C(2), paragraph 3(b), 20(3)(b), 12(5) of Eighth Schedule) Posted on January 23, 2019 by admin_kmos
BPR63 (ITA) – Interest incurred on loans obtained to acquire the shares of a company as opposed to acquiring the business of the company (Section 11(a), section 24J, section 23(f), section 23(g)) Posted on January 23, 2019 by admin_kmos
BPR64 (ITA) – Employees’ tax – Annuity payments from one long-term insurance company to another (Paragraph 1, paragraph 2 of Fourth Schedule) Posted on January 23, 2019 by admin_kmos
BPR65 (ITA) – Determination of residency for South African income tax purposes in the context of the term ‘ordinarily resident’ (“Resident” definition) Posted on January 23, 2019 by admin_kmos
BPR66 (ITA) – Deductibility of interest incurred on loans obtained to acquire the businesses of a group of companies as going concerns via acquisition of shares in a holding company (Section 24J(2)) Posted on January 23, 2019 by admin_kmos
BPR67 (ITA) – Foreign business establishment: Sharing of employees, equipment and facilities amongst controlled foreign companies which are part of the same group of companies (Section 9D(10)(a)(i)) Posted on January 23, 2019 by admin_kmos
BPR68 (ITA) – Classification of the extraction of clay from the soil (Section 15, section 36, section 37) Posted on January 23, 2019 by admin_kmos
BPR69 (VAT) – VAT implications regarding supply of services where mitigation services costs are received, the time of supply and the deduction of VAT charged (Sections 7(1)(a), 9(3), 16, 17, 20) Posted on January 23, 2019 by admin_kmos
BPR70 (ITA) – CGT implications for transfer of trust funds held by offshore trust to new offshore discretionary trust (Sections 7(8), 25D, 54, paragraphs 11, 38, 43, 72, 80, 84 Eighth Schedule) Posted on January 23, 2019 by admin_kmos