BPR109 (ITA) – Loan granted with embedded option (Section 22, section 24J, paragraph 18, paragraph 20(1)(a), paragraph 20(c)(ix), paragraph 35, paragraph 43, paragraph 58 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR110 (ITA) – Toll manufacturing agreement and the attribution of the global sales of South African manufactured products to a foreign business establishment (Section 9D(9)(b)(ii)(bb))

Posted on January 23, 2019 by admin_kmos

BPR111 (ITA) – Research and development (R&D) expenditure paid to a fellow group company which is not a resident of South Africa (Section 11(a), 11(a), section 35)

Posted on January 23, 2019 by admin_kmos

BPR112 (ITA) – Interposing a co-operative between a South African holding company and its foreign subsidiaries (Section 10(1)(k)(ii)(dd), section 24B, paragraph 64B of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR113 (ITA) – Expenditure associated with broad based black economic empowerment (BEE) (Section 11(a), section 23(g), section 23H)

Posted on January 23, 2019 by admin_kmos

BPR114 (ITA) – Loan facilities raised by a foreign permanent establishment from which deposits and advances are made (Section 24I, paragraph 43(1), Part XIII of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR115 (ITA) – Incentive rewards paid to independent sales persons (“Remuneration” definition, “employer” definition, “employee” definition, paragraph 2(1)(a) of Fourth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR116 (ITA) – Distribution received by beneficiary from a non-resident trust and subsequent donation thereof by beneficiary to another non-res trust (Sections 10(1)(k)(ii)(dd), 25B, 56(1)(g)(ii))

Posted on January 23, 2019 by admin_kmos

BPR118 (ITA) – Withholding dividends tax (“Dividend” definition, section 64D, section 64E, section 64F, section 64G, section 64H, section 64K)

Posted on January 23, 2019 by admin_kmos