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Category: Binding Private Rulings (BPR)

BPR211 (ITA) – Transfer of exchange items using corporate rules (Section 24I, section 42)

Posted on January 23, 2019 by admin_kmos
Posted in BPR211 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes) Transfer of exchange items using corporate rules

BPR212 (ITA) – Tax consequences for the issuer and security company of listed credit linked notes (Section 24J, paragraph 3, paragraph 4, paragraph 12A, paragraph 20(3)(b) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR212 (ITA) - Tax consequences for the issuer and security company of listed credit linked notes (Section 24J, paragraph 3, paragraph 4, paragraph 12A, paragraph 20(3)(b) of Eighth Schedule)

BPR213 (ITA) (STT) – ​Repayment of intercompany loans from proceeds of a new share issue (Sections 8(4)(a), 19, paragraph 12A of Eighth Schedule, “transfer” definition of STT Act)

Posted on January 23, 2019 by admin_kmos
Posted in BPR213 (ITA) (STT) - ​Repayment of intercompany loans from proceeds of a new share issue (Sections 8(4)(a), 19, paragraph 12A of Eighth Schedule, "transfer" definition of STT Act)

BPR214 (ITA) – ​Third-party backed shares (Section 8EA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR214 (ITA) - ​Third-party backed shares (Section 8EA)

BPR216 (ITA) – Tax consequences of the issuing of additional tier 1 capital instruments by a registered bank (Sections 8(4)(a), 8F, 8FA, 11(a), 19, 23(g), 24J, 24JB, paragraph 12A of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR216 (ITA) - Tax consequences of the issuing of additional tier 1 capital instruments by a registered bank (Sections 8(4)(a), 8F, 8FA, 11(a), 19, 23(g), 24J, 24JB, paragraph 12A of Eighth Schedule)

BPR217 (EDA) – ​Estate duty implications for non-resident individual investors (Section 2, section 3, section 4A of EDA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR217 (EDA) - ​Estate duty implications for non-resident individual investors (Section 2, section 3, section 4A of EDA)

BPR218 (ITA) – Qualifying distributions to be made by a REIT ​(“REIT” definition, section 25BB, section 44)

Posted on January 23, 2019 by admin_kmos
Posted in BPR218 (ITA) - Qualifying distributions to be made by a REIT ​("REIT” definition, section 25BB, section 44)

BPR219 (ITA) (STT) – ​Corporatisation of a collective investment scheme in property and an amalgamation followed by an asset-for-share transaction (Sections 25BB, 42, 44, 56(1)(r), section 8 of STT)

Posted on January 23, 2019 by admin_kmos
Posted in BPR219 (ITA) (STT) - ​(This ruling is only binding in respect of the specific applicant to whom it was issued and may not be relied upon by a third party) Corporatisation

BPR220 (ITA) – Contribution by a mining company to a trust pursuant to a share incentive scheme (Section 15. section 36(11))

Posted on January 23, 2019 by admin_kmos
Posted in BPR220 (ITA) - Contribution by a mining company to a trust pursuant to a share incentive scheme (Section 15. section 36(11))

BPR221 (ITA) – Deductibility of the cost of assets to be acquired to construct roads (Section 12C(1)(a))

Posted on January 23, 2019 by admin_kmos
Posted in BPR221 (ITA) - Deductibility of the cost of assets to be acquired to construct roads (Section 12C(1)(a))

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