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Category: Binding Private Rulings (BPR)

BPR19 (ITA) – Receipt of a cash payment from a trust – disposal of vested rights by the beneficiary for capital gains tax purposes​ (Paragraph 11 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR19 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes and policy guidance on the subject provided in Comprehensive guide to CGT) Trusts

BPR20 (ITA) – ​Impact that the transfer of an amount of share premium of a company to another reserve of that company has on the nature of the share premium (“Dividend” definition, section 64C)

Posted on January 23, 2019 by admin_kmos
Posted in BPR20 (ITA) - (The guidance contained in this ruling is affected by subsequent law changes) ​Transfer of an amount of share premium to another reserve - nature of share premium

BPR21 (ITA) – Date upon which restricted equity instruments vest and the date on which the liability to withhold employees’ tax arises (Section 8C, paragraphs 2, 11A of Fourth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR21 (ITA) - Date upon which restricted equity instruments vest and the date on which the liability to withhold employees' tax arises (Section 8C, paragraphs 2, 11A of Fourth Schedule)

BPR22 (ITA) – ​Taxation aspects of bonuses and penalties payable in terms of an employees’ bonus incentive and retention scheme (Sections 11(a), 23(g), 23H, paragraphs 1, 2 Fourth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR22 (ITA) - ​(The guidance contained in this ruling is affected by subsequent law changes) Bonuses and penalties payable in terms of an employees' bonus incentive and retention scheme

BPR23 (VAT) – ​Value-added tax implications to the parties relating to the establishment of a residential township development (Sections 7(1)(a), 12(c), 16(2), 16(3), 18(1), 23(1))

Posted on January 23, 2019 by admin_kmos
Posted in BPR23 (VAT) - ​Value-added tax implications to the parties relating to the establishment of a residential township development (Sections 7(1)(a), 12(c), 16(2), 16(3), 18(1), 23(1))

BPR24 (ITA) – ​Share for share relief provision (Section 41, section 43)

Posted on January 23, 2019 by admin_kmos
Posted in BPR24 (ITA) - ​(The guidance contained in this ruling is affected by subsequent law changes) Share for share relief provision (Section 41, section 43)

BPR25 (ITA) – ​The replacement of debt and the subsequent transfer thereof together with the assets in an asset-for-share-transaction (Section 42)

Posted on January 23, 2019 by admin_kmos
Posted in BPR25 (ITA) - ​The replacement of debt and the subsequent transfer thereof together with the assets in an asset-for-share-transaction (Section 42)

BPR26 (VAT) – Sale of land subject to a lease with assignment of that lease – going concern (Section 10(4), section 10(23), section 11(1)(e), section 18A(1))

Posted on January 23, 2019 by admin_kmos
Posted in BPR26 (VAT) - Sale of land subject to a lease with assignment of that lease - going concern (Section 10(4), section 10(23), section 11(1)(e), section 18A(1))

BPR27 (ITA) – ​Taxation aspects of an amalgamation transaction (Section 44(1))

Posted on January 23, 2019 by admin_kmos
Posted in BPR27 (ITA) - ​(The guidance contained in this ruling is affected by subsequent law changes) Taxation aspects of an amalgamation transaction (Section 44(1))

BPR28 (ITA) – ​Deduction of recurring expenditure incurred in terms of hybrid-debt instruments where the proceeds of such instruments rank as primary share capital for a bank (11(a), 23(g), 24J(2))

Posted on January 23, 2019 by admin_kmos
Posted in BPR28 (ITA) - ​Deduction of recurring expenditure incurred in terms of hybrid-debt instruments where the proceeds of such instruments rank as primary share capital for a bank (11(a), 23(g), 24J(2))

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