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Category: SARS Published Rulings

BPR149 (ITA) – Disposal of an asset that constitutes an equity share in a foreign company (“Contributed tax capital”, “asset-for-share transaction” definitions, paragraph 64B of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR149 (ITA) - (Replaced on 14 August 2013 - see SARS website) Disposal of an asset that constitutes an equity share in a foreign company

BPR150 (ITA) (VAT) – Tax treatment relating to a credit linked deposit (Section 11(a), section 23(g), section 24C, section 24J of ITA, section 7(1) of VAT Act)

Posted on January 23, 2019April 23, 2020 by admin_kmos
Posted in BPR150 (ITA) (VAT) - Tax treatment relating to a credit linked deposit (Section 11(a), section 23(g), section 24C, section 24J of ITA, section 7(1) of VAT Act)

BPR151 (ITA) (EDA) – Renunciation of an inheritance (Section 55(1), donation” definition, paragraph 11, paragraph 67(2) of Eighth Schedule, section 4(q) of EDA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR151 (ITA) (EDA) - Renunciation of an inheritance (Section 55(1), donation" definition, paragraph 11, paragraph 67(2) of Eighth Schedule, section 4(q) of EDA)

BPR32 (ITA) – Payments made to a third party for making available its manufacturing facility (Section 11(a), section 23(g), section 22)

Posted on January 23, 2019 by admin_kmos
Posted in BPR32 (ITA) - Payments made to a third party for making available its manufacturing facility (Section 11(a), section 23(g), section 22)

BPR33 (ITA) – Applicability of tax dispensations contained in the Act with regard to a specific contract mining agreement (Section 11(a), section 15, section 36, section 37A)

Posted on January 23, 2019 by admin_kmos
Posted in BPR33 (ITA) - Applicability of tax dispensations contained in the Act with regard to a specific contract mining agreement (Section 11(a), section 15, section 36, section 37A)

BPR34 (ITA) – Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement (Section 11(a), section 15, section 36, section 37A)

Posted on January 23, 2019 by admin_kmos
Posted in BPR34 (ITA) - Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement (Section 11(a), section 15, section 36, section 37A)

BPR35 (ITA) – Definition of group of companies and connected person (“Company” definition, “connected person” definition)

Posted on January 23, 2019 by admin_kmos
Posted in BPR35 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes) - group of companies and connected person

BPR36 (ITA) – Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement (Section 1, section 15, section 36)

Posted on January 23, 2019 by admin_kmos
Posted in BPR36 (ITA) - Applicability of tax dispensations contained in the Act with regard to a specific contract mining arrangement (Section 1, section 15, section 36)

BPR37 (ITA) – Disposal of the right to receive royalty income – an intra-group transaction or a debt cancellation (Section 45, paragraph 4(a), paragraphs 35, 12(5), 56(1), 38 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR37 (ITA) - Disposal of the right to receive royalty income - an intra-group transaction or a debt cancellation (Section 45, paragraph 4(a), paragraphs 35, 12(5), 56(1), 38 of Eighth Schedule)

BPR39 (ITA) – ​Unbundling transaction – the number of shares to be distributed and the distribution of shares to shareholders who are resident in certain foreign jurisdictions (Section 46)

Posted on January 23, 2019 by admin_kmos
Posted in BPR39 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes) - Unbundling transaction

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