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Category: Binding Private Rulings (BPR)

BPR162 (ITA) (VAT) – ​Sale of an oil and gas right (Paragraph 1 of Eighth Schedule, paragraph 1, paragraph 7 of Tenth Schedule, section 9, section 16 of VAT Act)

Posted on January 23, 2019 by admin_kmos
Posted in BPR162 (ITA) (VAT) - ​Sale of an oil and gas right (Paragraph 1 of Eighth Schedule, paragraph 1, paragraph 7 of Tenth Schedule, section 9, section 16 of VAT Act)

BPR163 (ITA) – ​Interest on replacement loans and proceeds arising from a share repurchase (“Contributed tax capital”, section 10(1)(k), 22B, 24J, 64F, paragraphs 35, 43A of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR163 (ITA) - ​Interest on replacement loans and proceeds arising from a share repurchase ("Contributed tax capital", section 10(1)(k), 22B, 24J, 64F, paragraphs 35, 43A of Eighth Schedule)

BPR164 (ITA) – Buy-back of shares at a purchase price in excess of their market value (Section 55, section 58, paragraph 38 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR164 (ITA) - Buy-back of shares at a purchase price in excess of their market value (Section 55, section 58, paragraph 38 of Eighth Schedule)

BPR83 (ITA) – ​Capital gains tax implications on the conversion of a company through the amendment of its incorporation documentation (Paragraph 11(1) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR83 (ITA) - ​Capital gains tax implications on the conversion of a company through the amendment of its incorporation documentation (Paragraph 11(1) of Eighth Schedule)

BPR84 (ITA) – The ‘group of companies’ concept for the purposes of section 45(4)

Posted on January 23, 2019 by admin_kmos
Posted in BPR84 (ITA) - The 'group of companies' concept for the purposes of section 45(4)

BPR85 (ITA) – ​Taxation aspects of income derived by non South African residents from employment in South Africa (Paragraph 2 of Fourth Schedule, India, USA, Czech, Romania, UK, Netherlands DTAs)

Posted on January 23, 2019 by admin_kmos
Posted in BPR85 (ITA) - ​Taxation aspects of income derived by non South African residents from employment in South Africa (Paragraph 2 of Fourth Schedule, India, USA, Czech, Romania, UK, Netherlands DTAs)

BPR86 (ITA) – Where two parties conduct mining operations in terms of an unincorporated joint venture agreement (Sections 1, 15, 24H, 36, 37A, paragraphs 1, 11, 33, 38 Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR86 (ITA) - Where two parties conduct mining operations in terms of an unincorporated joint venture agreement (Sections 1, 15, 24H, 36, 37A, paragraphs 1, 11, 33, 38 Eighth Schedule)

BPR87 (ITA) – ​Capital gains tax consequences arising from restructuring activities involving trusts (Paragraphs 80(1), 80(2) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR87 (ITA) - ​Capital gains tax consequences arising from restructuring activities involving trusts (Paragraphs 80(1), 80(2) of Eighth Schedule)

BPR88 (ITA) – Contributed capital of a foreign limited liability co-operative (“Equity share capital” definition)

Posted on January 23, 2019 by admin_kmos
Posted in BPR88 (ITA) - Contributed capital of a foreign limited liability co-operative ("Equity share capital" definition)

BPR89 (ITA) – ​Waiver of certain rights connected to shares (Sections 64B, paragraph 11(1)(b), paragraph 12(5)(a) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR89 (ITA) - ​Waiver of certain rights connected to shares (Sections 64B, paragraph 11(1)(b), paragraph 12(5)(a) of Eighth Schedule)

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