BCR79 (ITA) – Cancellation of share exchange (Paragraph 3(c), 4(c), 11(2)(o), 20(4) of Eighth Schedule of ITA)
Interpretation Note 120 (IN120) – Prohibition of deductions in respect of certain intellectual property (Section 23I)
Interpretation Note 119 (IN119) – Deductions in respect of improvements to land or buildings not owned by a taxpayer (Sections 12N, 12NA of ITA)
BPR372 (ITA) – Withholding tax on foreign royalties (Section 6quat(1A))
BPR374 (ITA) – Determination of group of companies (“Group of companies” definition)
BPR371 (ITA) – Public benefit activities carried on for the benefit of the general public (Section 30, “public benefit organisation” definition)
BPR373 (STT) – STT treatment of the proposed transfer of listed shares to the applicant in order to hedge its exposure under over-the-counter derivative transactions (Section 8(1)(q) of STT Act)
“Participation rights” definition of section 23M of ITA
“participation rights” means—
(a) the right to participate in all or part of the benefits of the rights (other than voting rights) attaching to a share, or any interest of a similar nature, in a company; or
(b) in the case where no person has any right in that company as contemplated in paragraph (a) or no such rights can be determined for any person, the right to exercise any voting rights in that company;
[Definition of “participation rights” inserted by section 19(1)(g) of Act 20 of 2021 effective on 31 March, 2023 and applicable in respect of years of assessment ending on or after that date (effective date in section 19(2) of Act 20 of 2021 as substituted by section 10 of Act 19 of 2022)]
“Debt” definition of section 23M of ITA
“debt” includes any amount in respect of which interest is determined or incurred, and such amount must be regarded as owed, but does not include a tax debt as defined in section 1(1) of the Tax Administration Act;
[Definition of “debt” inserted by section 19(1)(d) of Act 20 of 2021 effective on 31 March, 2023 and applicable in respect of years of assessment ending on or after that date (effective date in section 19(2) of Act 20 of 2021 as substituted by section 10 of Act 19 of 2022)]