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Category: Binding Private Rulings (BPR)

BPR222 (ITA) – ​Foreign partnership – Rebate in respect of foreign taxes on income (Section 6quat)

Posted on January 23, 2019 by admin_kmos
Posted in BPR222 (ITA) - ​Foreign partnership – Rebate in respect of foreign taxes on income (Section 6quat)

BPR223 (ITA) – ​Headquarter companies: Acquisitions of shares and loans (Section 8FA, section 9I(2)(b), section 9I(2)(c), section 20C(2), section 31(5))

Posted on January 23, 2019 by admin_kmos
Posted in BPR223 (ITA) - ​Headquarter companies: Acquisitions of shares and loans (Section 8FA, section 9I(2)(b), section 9I(2)(c), section 20C(2), section 31(5))

BPR224 (ITA) – Non-resident – Source of income from the operation of ships (“Gross income” definition, section 33)

Posted on January 23, 2019 by admin_kmos
Posted in BPR224 (ITA) - Non-resident – Source of income from the operation of ships ("Gross income" definition, section 33)

BPR225 (ITA) – Hybrid debt instruments (Section 8F, section 64D, section 64EA)

Posted on January 23, 2019 by admin_kmos
Posted in BPR225 (ITA) - Hybrid debt instruments (Section 8F, section 64D, section 64EA)

BPR226 (ITA) (VAT) (STT) – ​Transfer of the long-term insurance business, partly to a third party and partly intra-group (Sections 29A, 45, paragraphs 10(b), 12A, 35, 55(1)(a)(i) of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR226 (ITA) (VAT) (STT) - ​Transfer of the long-term insurance business, partly to a third party and partly intra-group (Sections 29A, 45, paragraphs 10(b), 12A, 35, 55(1)(a)(i) of Eighth Schedule)

BPR228 (ITA) – Whether an investment of preference share funding in a newly established business is for a “qualifying purpose” (Section 8EA(1), “operating company”, “qualifying purpose” definitions)

Posted on January 23, 2019 by admin_kmos
Posted in BPR228 (ITA) - Whether an investment of preference share funding in a newly established business is for a "qualifying purpose" (Section 8EA(1), "operating company", "qualifying purpose" definitions)

BPR229 (ITA) – Employer provided accommodation to employees (Paragraph 2(a), paragraph 5(1), paragraph 5(2), paragraph 5(3A) of Seventh Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR229 (ITA) - Employer provided accommodation to employees (Paragraph 2(a), paragraph 5(1), paragraph 5(2), paragraph 5(3A) of Seventh Schedule)

BPR230 (ITA) – ​Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an intra-group transaction (Section 42(1), section 42(2), section 45(5))

Posted on January 23, 2019 by admin_kmos
Posted in BPR230 (ITA) - ​Disposal of an asset in terms of an asset-for-share transaction within 18 months of its acquisition in terms of an intra-group transaction (Section 42(1), section 42(2), section 45(5))

BPR231 (ITA) (STT) – ​Corporate restructuring by way of asset-for-share and amalgamation transactions (Section 42. section 44, paragraph 11(2)(b)(i) of Eighth Schedule, section 8(1)(a)(ii) of STT Act)

Posted on January 23, 2019 by admin_kmos
Posted in BPR231 (ITA) (STT) - ​Corporate restructuring by way of asset-for-share and amalgamation transactions (Section 42. section 44, paragraph 11(2)(b)(i) of Eighth Schedule, section 8(1)(a)(ii) of STT Act)

BPR232 (ITA) – Equity shares to be issued by resultant company as part of an amalgamation transaction (“Equity share”, “amalgamation transaction” definitions, section 44(1))

Posted on January 23, 2019 by admin_kmos
Posted in BPR232 (ITA) - Equity shares to be issued by resultant company as part of an amalgamation transaction ("Equity share", "amalgamation transaction" definitions, section 44(1))

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