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Category: SARS Published Rulings

BPR225 (ITA) – Hybrid debt instruments (Section 8F, section 64D, section 64EA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR225 (ITA) - Hybrid debt instruments (Section 8F, section 64D, section 64EA)

BPR226 (ITA) (VAT) (STT) – ​Transfer of the long-term insurance business, partly to a third party and partly intra-group (Sections 29A, 45, paragraphs 10(b), 12A, 35, 55(1)(a)(i) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR226 (ITA) (VAT) (STT) - ​Transfer of the long-term insurance business, partly to a third party and partly intra-group (Sections 29A, 45, paragraphs 10(b), 12A, 35, 55(1)(a)(i) of Eighth Schedule)

BPR228 (ITA) – Whether an investment of preference share funding in a newly established business is for a “qualifying purpose” (Section 8EA(1), “operating company”, “qualifying purpose” definitions)

Posted on January 23, 2019 by admin_kmos
Posted in BPR228 (ITA) - Whether an investment of preference share funding in a newly established business is for a "qualifying purpose" (Section 8EA(1), "operating company", "qualifying purpose" definitions)

BPR229 (ITA) – Employer provided accommodation to employees (Paragraph 2(a), paragraph 5(1), paragraph 5(2), paragraph 5(3A) of Seventh Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR229 (ITA) - Employer provided accommodation to employees (Paragraph 2(a), paragraph 5(1), paragraph 5(2), paragraph 5(3A) of Seventh Schedule)

BPR230 (ITA) – ​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 (Section 42(1), section 42(2), section 45(5))

Posted on January 23, 2019 by admin_kmos
Posted in BPR230 (ITA) - ​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 (Section 42(1), section 42(2), section 45(5))

BPR231 (ITA) (STT) – ​Corporate restructuring by way of asset-for-share and amalgamation transactions (Section 42. section 44, paragraph 11(2)(b)(i) of Eighth Schedule, section 8(1)(a)(ii) of STT Act)

Posted on January 23, 2019 by admin_kmos
Posted in BPR231 (ITA) (STT) - ​Corporate restructuring by way of asset-for-share and amalgamation transactions (Section 42. section 44, paragraph 11(2)(b)(i) of Eighth Schedule, section 8(1)(a)(ii) of STT Act)

BPR232 (ITA) – Equity shares to be issued by resultant company as part of an amalgamation transaction (“Equity share”, “amalgamation transaction” definitions, section 44(1))

Posted on January 23, 2019 by admin_kmos
Posted in BPR232 (ITA) - Equity shares to be issued by resultant company as part of an amalgamation transaction ("Equity share", "amalgamation transaction" definitions, section 44(1))

BPR233 (ITA) – Transfer of a part of a business to a fellow subsidiary (Section 8(4)(a), section 11(a), section 24C, section 45(4B), paragraph 3(a), paragraph 4(a), 4(b)(ii)(aa) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR233 (ITA) - Transfer of a part of a business to a fellow subsidiary (Section 8(4)(a), section 11(a), section 24C, section 45(4B), paragraph 3(a), paragraph 4(a), 4(b)(ii)(aa) of Eighth Schedule)

BPR234 (ITA) (STT) – ​Asset-for-share and unbundling transactions not regulated by sections 42 and 46 (“Contributed tax capital” definition, paragraphs 11(2)(b), 39, 75 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR234 (ITA) (STT) - ​Asset-for-share and unbundling transactions not regulated by sections 42 and 46 ("Contributed tax capital" definition, paragraphs 11(2)(b), 39, 75 of Eighth Schedule)

BPR235 (ITA) – Income tax consequences for parties to an unbundling transaction (“Foreign company”, “resident”, section 9D, section 9H, section 42, section 46, paragraph 12 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR235 (ITA) - Income tax consequences for parties to an unbundling transaction ("Foreign company", "resident", section 9D, section 9H, section 42, section 46, paragraph 12 of Eighth Schedule)

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