Page 709 - SAIT Compendium 2016 Volume2

BRP RULING NO
063
094 113 122
160 161
175 145
154
172 123
180 202
068 182
173 193
208 008 184
006 042 114
002 045 057
DATE
24 November 2009
18 February 2011
15 March 2012
11 October 2012
22 January 2014 5 February 2015
30 July 2014 8 May 2013
3 September 2013
25 June 2014
11 October 2012
1 October 2014 14 August 2015
09 December 2009
6 November 2014
2 July 2014 15 June 2015
8 October 2015
6 March 2008
11 November 2014
6 March 2008 28 August 2009 19 March 2012
3 September 2007
25 September 2009
26 October 2009
NAME/SUBJECT
Interest incurred on loans obtained to acquire the shares of a company as opposed to acquiring the business of the company
Charges incurred in relation to the acquisition of trading stock
Expenditure associated with broad based black economic empowerment
Transfer of a business of a company as a going concern to its holding company as a result of an amalgamation or merger transaction
Incentive payments
Employee share ownership plan
Debt purchase transactions
Allowances - Assets forming part of a sale and leaseback arrangement
Corporate rules: Acquisition of a debtors book
Plant used in the production of renewable energy
Fibre optic cable to be used for electronic communications
Improvements effected on land not owned by taxpayer
Application of section 13quin subsequent to an intra- group transaction under section 45
Classi cation of the extraction of clay from the soil Waiver of debt that funded mining capital expenditure
Repayment of shareholder loan from proceeds of a new issue of ordinary shares
Debt reduction by way of set-off
Repayment of shareholder’s loan from proceeds of a new share issue
Certain variable payments made to a marketing executive and the application of s. 23 (m)
Asset-for-Share Transaction
The application of s. 24C in the context of a repair and maintenance contract
Determination of who quali es as a ‘ lm owner’ for purposes of s. 24F
Loan facilities raised by a foreign permanent establishment from which deposits and advances are made
Method for determination of the interest amount that accrues on the collection of a distressed debtors book
Deductibility of conditional interest incurred in terms of a loan
Interest incurred on a loan obtained to acquire the business of a company as a going concern through the acquisition of the shares of the company
SECTION OF INCOME TAX ACT
Sections 11 (a), 24J and 23 (f) and (g)
Sections 11 (a), 22 and 23 (g) Sections 11 (a), 23 (g) and 23H
Sections 11 (a), 23 (g), 45, 47 and 64FA (1) (b), para. 38 of the Eighth Schedule to the Act, and s. 2 of the STT Act
Section 11 (a)
Sections 11 (a), 23 (g), 54 and 58. Paragraphs 2(1) and 11A (4) of the Fourth Schedule
Sections 11 (a), 23 (g), and 24J Section 11 (e)
Sections 11 (j) and 45 Section 12B
Section 12D, de nition of ‘affected asset’
Section 12N
Sections 13quin and 45 (3)
Sections 15, 36 and 37
Section 15(a) read with ss. 36, 19 and para. 12A of the Eighth Schedule
Section 19 and para. 12A of the Eighth Schedule
Section 19 de nition of ‘reduction amount’ and paras. 12A and 20 (3) (b) of the 8th Schedule
Section 19 and para. 12A of the 8th Schedule
Section 23 (m)
Sections 24BA, 42, 54 and 58 and para. 38 of the Eighth Schedule
Section 24C Section 24F
Section 24I, para. 43 (1) and Part XIII of the Eighth Schedule
Section 24J
Sections 24J and 11 (a) read
with s. 23 (g) Section 24J