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Recent binding rulings

South Africa

Taxand South Africa presents an update on recent rulings.

SARS has recently released, inter alia, the following binding private rulings (BPR), binding class rulings (BCR) and binding general rulings (BGR):

  • BPR 217: Estate duty implications for non-resident individual investors
  • BPR 218: Qualifying distributions to be made by a REIT
  • BPR 219: Corporatisation of a collective investment scheme in property and an amalgamation followed by an asset-for-share transaction
  • BPR 220: Contribution by a mining company to a trust pursuant to a share incentive scheme
  • BPR 222: Foreign partnership – rebate in respect of foreign taxes on income
  • BPR 223: Headquarter companies – acquisitions of shares and loans
  • BPR 225: Hybrid debt instruments
  • BPR 227: Share subscription transaction followed by two share repurchase transactions
  • BCR 050: Tax consequences for unitholders in a REIT of an amalgamation transaction, followed by an asset-for-share transaction
  • BCR 051: Taxation of employees participating in a perpetuity employee share incentive scheme
  • BGR 11 (Issue 2): Use of an exchange rate
  • Draft BGR: Electronic services supplied via intermediaries

Discover more: Recent binding rulings
Discover more: Tax in brief


Your Taxand contacts for further queries are:
Bernard Du Plessis
T. +27 21 410 2500
E. bduplessis@ENSafrica.com

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Taxand's Take

Taxpayers in South Africa should take note of this update to ensure they remain compliant.

Taxand's Take Author

Bernard Du Plessis
Taxand Board member
South Africa
Sub-Saharan Africa

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