BPR110 (ITA) – Toll manufacturing agreement and the attribution of the global sales of South African manufactured products to a foreign business establishment (Section 9D(9)(b)(ii)(bb))

Posted on January 23, 2019 by admin_kmos

BPR111 (ITA) – Research and development (R&D) expenditure paid to a fellow group company which is not a resident of South Africa (Section 11(a), 11(a), section 35)

Posted on January 23, 2019 by admin_kmos

BPR112 (ITA) – Interposing a co-operative between a South African holding company and its foreign subsidiaries (Section 10(1)(k)(ii)(dd), section 24B, paragraph 64B of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR113 (ITA) – Expenditure associated with broad based black economic empowerment (BEE) (Section 11(a), section 23(g), section 23H)

Posted on January 23, 2019 by admin_kmos

BPR114 (ITA) – Loan facilities raised by a foreign permanent establishment from which deposits and advances are made (Section 24I, paragraph 43(1), Part XIII of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR115 (ITA) – Incentive rewards paid to independent sales persons (“Remuneration” definition, “employer” definition, “employee” definition, paragraph 2(1)(a) of Fourth Schedule)

Posted on January 23, 2019 by admin_kmos

BPR116 (ITA) – Distribution received by beneficiary from a non-resident trust and subsequent donation thereof by beneficiary to another non-res trust (Sections 10(1)(k)(ii)(dd), 25B, 56(1)(g)(ii))

Posted on January 23, 2019 by admin_kmos

BPR118 (ITA) – Withholding dividends tax (“Dividend” definition, section 64D, section 64E, section 64F, section 64G, section 64H, section 64K)

Posted on January 23, 2019 by admin_kmos

BPR119 (ITA) – Transfer of amounts contributed to a foreign pension fund to as SA retirement annuity fund (Sections 9(1)(g), 10(1)(gC), 11(k), 11(n), paragraphs 2(1)(a), 5 of Second Schedule)

Posted on January 23, 2019 by admin_kmos