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Category: SARS Published Rulings

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
Posted in BPR65 (ITA) - Determination of residency for South African income tax purposes in the context of the term 'ordinarily resident' ("Resident" definition)

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
Posted in 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))

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
Posted in 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))

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
Posted in BPR68 (ITA) - Classification of the extraction of clay from the soil (Section 15, section 36, section 37)

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
Posted in 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)

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
Posted in 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)

BPR71 (ITA) – ​Improvements effected on leasehold property (Paragraph (h) of “gross income” definition)

Posted on January 23, 2019 by admin_kmos
Posted in BPR71 (ITA) - ​Improvements effected on leasehold property (Paragraph (h) of "gross income" definition)

BPR72 (VAT) – VAT implications with regard to qualified goods imported for processing and the subsequent exportation of the end products (Section 13(3))

Posted on January 23, 2019 by admin_kmos
Posted in BPR72 (VAT) - VAT implications with regard to qualified goods imported for processing and the subsequent exportation of the end products (Section 13(3))

BPR73 (ITA) – Extinction of inter-company loans as a result of voluntary winding-up (Section 8(4)(m), section 20(1)(a)(ii), paragraph 12(5) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR73 (ITA) - Extinction of inter-company loans as a result of voluntary winding-up (Section 8(4)(m), section 20(1)(a)(ii), paragraph 12(5) of Eighth Schedule)

BPR74 (ITA) – ​Date upon which shares vest in a taxpayer and related interest expense (Section 8C)

Posted on January 23, 2019 by admin_kmos
Posted in BPR74 (ITA) - ​Date upon which shares vest in a taxpayer and related interest expense (Section 8C)

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