Page 706 - SAIT Compendium 2016 Volume2

BRP RULING NO
DATE
NAME/SUBJECT
SECTION OF INCOME TAX ACT
156
3 October 2013
Pension bene ts accruing to a non-resident from a resident pension fund
Section 1 (1), de nition of ‘gross income’ paras. (a) and (e)
167
2 April 2014
Debentures tracking the value of a reference asset
Sections 1 (1), de nition of ‘gross income’ and Paragraph (a) of the de nition of ‘trading stock’, 11 (a) read with 23 (g) and 22 (1) (a)
174
29 July 2014
Receipts of an incentive trust and vesting of shares in qualifying employees
Section 1(1), de nition of ‘gross income’ and Paragraph 11 (1) (d) read with paragraphs 20 (1) (h) (i) and 80 (1) of the Eighth Schedule
177
31 July 2014
Improvements on land by sub-lessee under a sub-lease
Sections 1 (1) de nition of ‘gross income’, 11 (g) and 11 (h)
179
15 August 2014
Single premium life insurance policy issued by an off- shore insurer
Sections 1 (1) de nition of ‘gross income’ and 7 (1) and Paragraphs 11 (1), 35 (1), 40 and 55 of the Eighth Schedule
183
6 November 2014
Employee Housing Scheme
Section 1 (1) de nition of ‘gross income’, paragraphs (c) and (i), and paragraphs 2 (a) and 2(d) of the Seventh Schedule
187
18 February 2015
Waiver of and intra-group loan that funded the acquisition of mining operation
Sections 1 (1), de nition of ‘gross income’, 8 (4) (a),
15 (a),19, 36, 45 and paragraphs 12A, 38 (1) and 56 (1) of the 8th Schedule
194
15 June 2015
Disposal of shares through a share buy-back and a donation
Sections 1 (1) de nitions of ‘gross income’ and ‘dividend’, 18A, 54, 56 (1) (h), 64D de nition of ‘dividend’ and paragraphs 2 (1), 11 (1) and 2 (b) of the 8th Schedule
165
18 March 2014
Letting of accommodation where the provision of meals is outsourced
Sections 1 (1), de nition of ‘hotel keeper’ and 13bis
196
1 July 2015
Employees’ tax – Monthly pension bene ts in respect of foreign services rendered
Sections 1 (1) de nition of ‘income’, 9 (2) (i), 10 (1) (gC) (ii) and paragraphs 1 de nition of ‘remuneration’ and 2(1) of the 4th Schedule
200
3 August 2015
Source of income of commission payable to non- resident junket agents
Sections 1 (1) de nition of ‘gross income’, 47A and 51A
201
13 August 2015
Issue of capitalization shares
Sections 1 (1) de nition of ‘gross income’ paragraphs
(c) and (k), ‘contributed tax capital’, ‘dividend’ and ‘return of capital’, 8C, 40C, 42 (5) and (6) and paragraph 11 of the 8th Schedule
146
10 May 2013
Mining tax – Contract mining agreement
Sections 1, de nition of ‘mining operations’ and/or ‘mining’, 11 (a), 15 (a), 23 (g), 36 and 37A (1) (d) (ii)
102
04 May 2011
Registration of an external company and identifying a permanent establishment
Section 1 de nition of ‘permanent establishment’, s. 10 (1) (h) and para. 2 (1) of the Eighth Schedule
155
6 September 2013
Incentive for oil and gas production
Paragraph 1, de nition of ‘production’, ‘oil and gas right’ and ‘oil and gas income’ and para. 5 (2) (b) of the Tenth Schedule