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

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Taxand's Take

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

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Article tags

International Tax | South Africa

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