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Category: Binding Private Rulings (BPR)

BPR90 (ITA) – Royalty income attributable to a foreign business establishment of a controlled foreign company (Section 9D(10)(a)(iii))

Posted on January 23, 2019 by admin_kmos
Posted in BPR90 (ITA) - Royalty income attributable to a foreign business establishment of a controlled foreign company (Section 9D(10)(a)(iii))

BPR91 (ITA) – ​Securities lending transaction (Section 24J)

Posted on January 23, 2019 by admin_kmos
Posted in BPR91 (ITA) - ​Securities lending transaction (Section 24J)

BPR92 (ITA) – ​Possible recoupment of rental paid on the subsequent acquisition of the leased property by the lessee (Section 8(5)(b))

Posted on January 23, 2019 by admin_kmos
Posted in BPR92 (ITA) - ​Possible recoupment of rental paid on the subsequent acquisition of the leased property by the lessee (Section 8(5)(b))

BPR93 (ITA) – ​Deductibility of environmental expenditure subsequently incurred in respect of asset that have been acquired in an asset-for-share transaction (Section 37B(6), section 42(3)(a)(ii))

Posted on January 23, 2019 by admin_kmos
Posted in BPR93 (ITA) - ​Deductibility of environmental expenditure subsequently incurred in respect of asset that have been acquired in an asset-for-share transaction (Section 37B(6), section 42(3)(a)(ii))

BPR94 (ITA) – ​Charges incurred in relation to the acquisition of trading stock (Section 11(a), section 22, section 23(g))

Posted on January 23, 2019 by admin_kmos
Posted in BPR94 (ITA) - ​Charges incurred in relation to the acquisition of trading stock (Section 11(a), section 22, section 23(g))

BPR95 (ITA) – ​Adequate consideration as contemplated under section 58(1)

Posted on January 23, 2019 by admin_kmos
Posted in BPR95 (ITA) - ​Adequate consideration as contemplated under section 58(1)

BPR96 (ITA) – ​Group restructuring transactions and possible relief measures (Section 46, section 47, section 64B(5)(f))

Posted on January 23, 2019 by admin_kmos
Posted in BPR96 (ITA) - ​Group restructuring transactions and possible relief measures (Section 46, section 47, section 64B(5)(f))

BPR97 (ITA) – Capital gains tax liability in relation to assets of a trust which vest in the hands of the vesting beneficiaries (Paragraphs 11, 13, 20, 31, 38, 62, 80 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR97 (ITA) - Capital gains tax liability in relation to assets of a trust which vest in the hands of the vesting beneficiaries (Paragraphs 11, 13, 20, 31, 38, 62, 80 of Eighth Schedule)

BPR99 (STT) – ​Transfer of beneficial ownership of South African listed shares under a ‘riskless principal’ transaction (“Transfer” definition)

Posted on January 23, 2019 by admin_kmos
Posted in BPR99 (STT) - ​Transfer of beneficial ownership of South African listed shares under a 'riskless principal' transaction ("Transfer" definition)

BPR98 (ITA) – ​Capital gain or loss on ceded policies (Paragraph 55(1)(a)(ii) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR98 (ITA) - ​Capital gain or loss on ceded policies (Paragraph 55(1)(a)(ii) of Eighth Schedule)

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