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Category: SARS Published Rulings

BPR119 (ITA) – ​Transfer of amounts contributed to a foreign pension fund to as SA retirement annuity fund (Sections 9(1)(g), 10(1)(gC), 11(k), 11(n), paragraphs 2(1)(a), 5 of Second Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR119 (ITA) - ​Transfer of amounts contributed to a foreign pension fund to as SA retirement annuity fund (Sections 9(1)(g), 10(1)(gC), 11(k), 11(n), paragraphs 2(1)(a), 5 of Second Schedule)

BPR120 (ITA) – ​The interaction between sections 45 and section 24J in the transfer of interest-bearing receivables under the corporate rules

Posted on January 23, 2019 by admin_kmos
Posted in BPR120 (ITA) - ​The interaction between sections 45 and section 24J in the transfer of interest-bearing receivables under the corporate rules

BPR121 (ITA) – Secondary tax on companies or dividends tax (Section 64B(1), “declared” definition, section 64E(1), section 64D)

Posted on January 23, 2019 by admin_kmos
Posted in BPR121 (ITA) - Secondary tax on companies or dividends tax (Section 64B(1), “declared” definition, section 64E(1), section 64D)

BPR122 (ITA) (STT) – Transfer of business of company as going concern to its holdco as a result of an amalgamation or merger transaction (Section 45, 47, 64FA, paragraph 38 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR122 (ITA) (STT) - Transfer of business of company as going concern to its holdco as a result of an amalgamation or merger transaction (Section 45, 47, 64FA, paragraph 38 of Eighth Schedule)

BPR123 (ITA) – ​Fibre optic cable to be used for electronic communications (“Affected asset” definition, section 12D)

Posted on January 23, 2019 by admin_kmos
Posted in BPR123 (ITA) - ​Fibre optic cable to be used for electronic communications ("Affected asset" definition, section 12D)

BPR124 (ITA) – ​Repayment of shareholders’ loans from proceeds of issue of redeemable preference shares (“Contributed tax capital”, section 20(1)(a)(ii), paragraphs 12(5), 20(1)(a) Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR124 (ITA) - ​Repayment of shareholders' loans from proceeds of issue of redeemable preference shares (“Contributed tax capital”, section 20(1)(a)(ii), paragraphs 12(5), 20(1)(a) Eighth Schedule)

BPR125 (ITA) – Vesting by discretionary trust of dividend rights to beneficiary (Sections 10(1)(t)(vii), 64D, “beneficial owner” definition, 64F(g) 64G(2)(a), paragraphs 63, 80(1) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR125 (ITA) - Vesting by discretionary trust of dividend rights to beneficiary (Sections 10(1)(t)(vii), 64D, "beneficial owner" definition, 64F(g) 64G(2)(a), paragraphs 63, 80(1) of Eighth Schedule)

BPR126 (ITA) (VAT) (STT) – Disposal of a business and investment shares as a result of restructuring, and the distribution of certain shares to shareholders (Section 42, section 46)

Posted on January 23, 2019 by admin_kmos
Posted in BPR126 (ITA) (VAT) (STT) - Disposal of a business and investment shares as a result of restructuring, and the distribution of certain shares to shareholders (Section 42, section 46)

BPR127 (ITA) – ​Relief from double taxation of foreign income (Section 5, section 10, section 24J, section 108, Zambia DTA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR127 (ITA) - ​Relief from double taxation of foreign income (Section 5, section 10, section 24J, section 108, Zambia DTA)

BPR128 (ITA) – ​Disposal of equity shares in a foreign company (Section 41(1), “financial instrument”, “associated group companies”, “foreign financial instrument holding company” definitions)

Posted on January 23, 2019 by admin_kmos
Posted in BPR128 (ITA) - ​Disposal of equity shares in a foreign company (Section 41(1), “financial instrument”, “associated group companies”, “foreign financial instrument holding company” definitions)

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