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Category: SARS Published Rulings

BPR178 (ITA) – ​International corporate restructuring (“Company”, “equity share”, “foreign company”, “group of companies”, “share” definitions, section 42, section 45)

Posted on January 23, 2019 by admin_kmos
Posted in BPR178 (ITA) - ​International corporate restructuring (“Company”, “equity share”, “foreign company”, “group of companies”, “share” definitions, section 42, section 45)

BPR179 (ITA) – Single premium life insurance policy issued by an off-shore insurer (Section 7(1), paragraph 11(1), paragraph 35(1), paragraph 40, paragraph 55 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR179 (ITA) - Single premium life insurance policy issued by an off-shore insurer (Section 7(1), paragraph 11(1), paragraph 35(1), paragraph 40, paragraph 55 of Eighth Schedule)

BPR180 (ITA) – ​Improvements effected on land not owned by taxpayer (Section 12N)

Posted on January 23, 2019 by admin_kmos
Posted in BPR180 (ITA) - ​Improvements effected on land not owned by taxpayer (Section 12N)

BPR181 (ITA) – Withholding tax on interest in relation to a foreign government (“Resident”, sections 9(2)(b), 24J(1), “interest”, section 50A(1), “foreign person”, sections 50B, 50E, Denmark DTA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR181 (ITA) - Withholding tax on interest in relation to a foreign government (“Resident”, sections 9(2)(b), 24J(1), “interest”, section 50A(1), “foreign person”, sections 50B, 50E, Denmark DTA)

BPR182 (ITA) – ​Waiver of debt that funded mining capital expenditure (Section 15(a), section 36, section 19, paragraph 12A of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR182 (ITA) - ​Waiver of debt that funded mining capital expenditure (Section 15(a), section 36, section 19, paragraph 12A of Eighth Schedule)

BPR183 (ITA) – ​Employee Housing Scheme (Paragraph (c), paragraph (i) of “gross income” definition, 2(a), paragraph 2(d) of Seventh Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR183 (ITA) - ​Employee Housing Scheme (Paragraph (c), paragraph (i) of "gross income" definition, 2(a), paragraph 2(d) of Seventh Schedule)

BPR184 (ITA) – Asset-for-Share Transaction (Section 24BA, section 42, section 54, section 58, paragraph 38 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR184 (ITA) - Asset-for-Share Transaction (Section 24BA, section 42, section 54, section 58, paragraph 38 of Eighth Schedule)

BPR185 (ITA) – ​Corporate Rules: Disposal of assets and liabilities as part of a group restructure (Section 7B, section 11(a), section 23(g), section 37A, section 42)

Posted on January 23, 2019 by admin_kmos
Posted in BPR185 (ITA) - ​Corporate Rules: Disposal of assets and liabilities as part of a group restructure (Section 7B, section 11(a), section 23(g), section 37A, section 42)

BPR186 (ITA) (STT) – Asset-for-Share transaction between a resident private company and a collective investment scheme (CIS) in securities (Section 24J, 41, 42 of ITA Act, section 1, 8 of STT Act)

Posted on January 23, 2019 by admin_kmos
Posted in BPR186 (ITA) (STT) - Asset-for-Share transaction between a resident private company and a collective investment scheme (CIS) in securities (Section 24J, 41, 42 of ITA Act, section 1, 8 of STT Act)

BPR187 (ITA) – Waiver of an intra-group loan that funded the acquisition of a mining operation (Sections 8(4)(a), 15(a) 19, 36, 45, paragraphs 12A, 38(1), 56(1) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR187 (ITA) - Waiver of an intra-group loan that funded the acquisition of a mining operation (Sections 8(4)(a), 15(a) 19, 36, 45, paragraphs 12A, 38(1), 56(1) of Eighth Schedule)

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