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Category: Binding Private Rulings (BPR)

BPR387 (ITA) – Attribution of nett income to a public benefit organisation (Sections 9D, 10(1)(cN))

Posted on December 28, 2022 by admin_kmos
Posted in BPR387 (ITA) - Attribution of nett income to a public benefit organisation (Sections 9D, 10(1)(cN))

BPR384 (ITA) – Cession to special trust of the beneficiary’s loan account (“Donation” definition, sections 54, 55, paragraphs 38, 39 of Eighth Schedule)

Posted on November 23, 2022 by admin_kmos
Posted in BPR384 (ITA) - Cession to special trust of the beneficiary’s loan account ("Donation" definition, sections 54, 55, paragraphs 38, 39 of Eighth Schedule)

BPR383 (ITA) – Transfer of profits for group tax purposes between controlled foreign companies (Sections 9D(2A) and 9D(9))

Posted on November 23, 2022 by admin_kmos
Posted in BPR383 (ITA) - Transfer of profits for group tax purposes between controlled foreign companies (Sections 9D(2A) and 9D(9))

BPR385 (ITA) – Use of preference share proceeds to fund employee share ownership plan (“Gross income”, “instrument”, sections 8E, 8EA, 10, 24J, 54, 58, 64F, 64G, paragraphs 19, 20, 38, 39, 43A, 80 of Eighth Schedule)

Posted on November 23, 2022 by admin_kmos
Posted in BPR385 (ITA) - Use of preference share proceeds to fund employee share ownership plan ("Gross income", "instrument", sec 8E, 8EA, 10, 24J, 54, 58, 64F, 64G, para 19, 20, 38, 39, 43A, 80 of Eighth Sch)

BPR386 (ITA) – Share disposal between two employee share incentive trusts (“Connected person” definition, sections 54, 58(1), paragraph 38 of Eighth Schedule)

Posted on November 23, 2022 by admin_kmos
Posted in BPR386 (ITA) - Share disposal between two employee share incentive trusts ("Connected person" definition, sections 54, 58(1), paragraph 38 of Eighth Schedule)

BPR379 (ITA) – Qualifying purpose (Sections 8E, 8EA)

Posted on October 24, 2022 by admin_kmos
Posted in BPR379 (ITA) - Qualifying purpose (Sections 8E, 8EA)

BPR382 (ITA) – Rebate in respect of foreign taxes (Section 6quat, paragraphs 2, 35 of Eighth Schedule of Act)

Posted on October 24, 2022 by admin_kmos
Posted in BPR382 (ITA) - Rebate in respect of foreign taxes (Section 6quat, paragraphs 2, 35 of Eighth Schedule of Act)

BPR381 (STT) – Beneficial ownership in respect of back-to-back share transfers (Section 1 “transfer”, “unrestricted and security restricted stock account” definitions, sections 2(1), 8(1)(q))

Posted on October 24, 2022 by admin_kmos
Posted in BPR381 (STT) - Beneficial ownership in respect of back-to-back share transfers (Section 1 “transfer”, “unrestricted and security restricted stock account” definitions, sections 2(1), 8(1)(q))

BPR380 (ITA) – Transfer of shares in resident company to non-resident holding company (Sections 9D, 64E, paragraphs 38, 39, 76B of Eighth Schedule of Act)

Posted on October 24, 2022 by admin_kmos
Posted in BPR380 (ITA) - Transfer of shares in resident company to non-resident holding company (Sections 9D, 64E, paragraphs 38, 39, 76B of Eighth Schedule of Act)

BPR378 (ITA) (STT) – Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests (Sections 9C, 42, para 61(3) of Eighth Sch, section 8 of STT)

Posted on September 23, 2022 by admin_kmos
Posted in BPR378 (ITA) (STT) - Transfer of listed financial instruments to collective investment schemes in exchange for participatory interests (Sections 9C, 42, para 61(3) of Eighth Sch, section 8 of STT)

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