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Category: SARS Published Rulings

BCR12 (ITA) – ​Income tax implications attendant upon the vesting of an ‘equity instrument’ listed on a foreign stock exchange (Section 8C, section 6quat, section 7(1))

Posted on January 23, 2019 by admin_kmos
Posted in BCR12 (ITA) - ​Income tax implications attendant upon the vesting of an 'equity instrument' listed on a foreign stock exchange (Section 8C, section 6quat, section 7(1))

BCR13 (ITA) – Nature of dividend income when distribution by a discretionary trust to income beneficiaries by virtue of employment (“Gross income” defintion, section 10(1)(k)(i), section 25B)

Posted on January 23, 2019 by admin_kmos
Posted in BCR13 (ITA) - Nature of dividend income when distribution by a discretionary trust to income beneficiaries by virtue of employment (“Gross income” defintion, section 10(1)(k)(i), section 25B)

BCR14 (ITA) – ​Deductibility of interest incurred in respect of a loan entered into to purchase restricted equity instruments in a share purchase scheme (8C, 10(1)(nE), 23(m), 24J(2), paragraph 20, 76 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BCR14 (ITA) - ​Deductibility of interest incurred in respect of a loan entered into to purchase restricted equity instruments in a share purchase scheme (8C, 10(1)(nE), 23(m), 24J(2), para 20, 76)

BCR15 (ITA) – Repealed legislation and the application of section 12(1) of the Interpretation Act, 1957 (Act No. 33 of 1957) (Section 27 (5B))

Posted on January 23, 2019 by admin_kmos
Posted in BCR15 (ITA) - Repealed legislation and the application of section 12(1) of the Interpretation Act, 1957 (Act No. 33 of 1957) (Section 27 (5B))

BCR16 (ITA) – Capital gains tax – Re-designation of preference shares (Paragraph 11, paragraph 33, paragraph 35 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BCR16 (ITA) - Capital gains tax - Re-designation of preference shares (Paragraph 11, paragraph 33, paragraph 35 of Eighth Schedule)

BCR17 (ITA) – ​Creation of a permanent establishment if a foreign partnership carries on business in SA (“Gross income” definition, section 10(1)(h), 10(1)(k)(i), paragraph 2 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BCR17 (ITA) - ​Creation of a permanent establishment if a foreign partnership carries on business in SA (“Gross income” definition, section 10(1)(h), 10(1)(k)(i), paragraph 2 of Eighth Schedule)

BCR18 (ITA) – Overseas incentive trips for employees with both business and private elements and related taxable benefit implications (Paragraphs 1, 2(c), 2(d), 2(e), 8, 9, 10 of Seventh Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BCR18 (ITA) - Overseas incentive trips for employees with both business and private elements and related taxable benefit implications (Paragraphs 1, 2(c), 2(d), 2(e), 8, 9, 10 of Seventh Schedule)

BCR19 (ITA) – ​Accrual date of a liquidation benefit (“Gross income” definition, “retirement lump sum withdrawal benefit” definition, section 10(1)(i)(xv)(bb), paragraph 2(b) of Second Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BCR19 (ITA) - ​Accrual date of a liquidation benefit ("Gross income" definition, “retirement lump sum withdrawal benefit” definition, section 10(1)(i)(xv)(bb), paragraph 2(b) of Second Schedule)

BCR20 (ITA) – Transfer of pension and provident fund contributions from South African pension and provident funds to foreign pension and provident funds (Section 9(1)(g))

Posted on January 23, 2019January 23, 2019 by admin_kmos
Posted in BCR20 (ITA) - Transfer of pension and provident fund contributions from South African pension and provident funds to foreign pension and provident funds (Section 9(1)(g))

BCR22 (ITA) – ​Potential double taxation of profits attributable to protected cell companies (“Company” definition, section 9D)

Posted on January 23, 2019January 23, 2019 by admin_kmos
Posted in BCR22 (ITA) - ​Potential double taxation of profits attributable to protected cell companies ("Company" definition, section 9D)

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