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Category: Binding Private Rulings (BPR)

BPR190 (ITA) (STT) – ​Notional Funding Arrangement: The issue and potential repurchase of ordinary shares (Section 24J, paragraph 11(1)(a), paragraph 35 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR190 (ITA) (STT) - ​Notional Funding Arrangement: The issue and potential repurchase of ordinary shares (Section 24J, paragraph 11(1)(a), paragraph 35 of Eighth Schedule)

BPR191 (ITA) – Refinancing of debt through preference share funding (Section 8E, section 8EA, section 19, paragraph 12A of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR191 (ITA) - Refinancing of debt through preference share funding (Section 8E, section 8EA, section 19, paragraph 12A of Eighth Schedule)

BPR192 (ITA) – Cross border interest-free loan and withholding tax on interest (Section 31, section 50B, section 50E)

Posted on January 23, 2019 by admin_kmos
Posted in BPR192 (ITA) - Cross border interest-free loan and withholding tax on interest (Section 31, section 50B, section 50E)

BPR193 (ITA) – ​Debt reduction by way of set-off (Section 19 definition of “reduction amount”, paragraph 12A, paragraph 20(3)(b) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR193 (ITA) - ​Debt reduction by way of set-off (Section 19 definition of "reduction amount", paragraph 12A, paragraph 20(3)(b) of Eighth Schedule)

BPR194 (ITA) (STT) – Disposal of shares through a share buy-back and a donation (Sections 18A, 54, 56(1)(h), 64D, “dividend” definition, paragraphs 2(1), 11(1) AND 11(2)(b) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR194 (ITA) (STT) - Disposal of shares through a share buy-back and a donation (Sections 18A, 54, 56(1)(h), 64D, "dividend" definition, paragraphs 2(1), 11(1) AND 11(2)(b) of Eighth Schedule)

BPR195 (ITA) (STT) – ​Securities transfer tax exemption where election has been made that section 42 will not apply (Sections 40CA, 42, paragraphs 2(1)(b), 20(1)(a) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR195 (ITA) (STT) - ​Securities transfer tax exemption where election has been made that section 42 will not apply (Sections 40CA, 42, paragraphs 2(1)(b), 20(1)(a) of Eighth Schedule)

BPR196 (ITA) – Employees’ Tax: Monthly pension benefits in respect of foreign services rendered​ (Sections 9(2)(i), 10(1)(gC)(ii), “remuneration” definition, paragraph 2(1) of Fourth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR196 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes) Employees' Tax: Monthly pension benefits in respect of foreign services rendered​

BPR197 (ITA) (EDA) – ​Exemption from donations tax and net value of an estate (Section 56(1)(g)(ii) of ITA, section 4(e)(ii)(aa), section 4(e)(iii) of EDA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR197 (ITA) (EDA) - ​Exemption from donations tax and net value of an estate (Section 56(1)(g)(ii) of ITA, section 4(e)(ii)(aa), section 4(e)(iii) of EDA)

BPR198 (ITA) – ​Distribution of a debit loan account in anticipation of deregistration of a company (Section 10(1)(k), section 47, section 64D, section 64FA(1)(b))

Posted on January 23, 2019 by admin_kmos
Posted in BPR198 (ITA) - ​Distribution of a debit loan account in anticipation of deregistration of a company (Section 10(1)(k), section 47, section 64D, section 64FA(1)(b))

BPR199 (ITA) – Exemption from income tax of dividends received by virtue of restricted equity instruments (Section 8C(7), “restricted equity instrument” definition, section 10(1)(k)(i))

Posted on January 23, 2019 by admin_kmos
Posted in BPR199 (ITA) - Exemption from income tax of dividends received by virtue of restricted equity instruments (Section 8C(7), “restricted equity instrument” definition, section 10(1)(k)(i))

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