Page 715 - SAIT Compendium 2016 Volume2

BC RULING NO
DATE
NAME/SUBJECT
SECTION OF INCOME TAX ACT
043
20 February 2014
Antecedent cession of rights to future production rebate credit certi cates (PRCCs)
Section 1 (1), de nition of ‘gross income’
044
2 May 2014
Repurchase of non-redeemable, non-participating preference shares
Note:
BCR 044 has been replaced on 20 May 2014 to provide for textual changes and additions to the original ruling for improved clarity - refer to paragraph 5 and third bullet point in paragraph 7
Section 1 (1), de nition of ‘equity share’; section 8E and paragraph 11 (2) (b) of the Eighth Schedule
(Also section 2(1) of the STT Act)
045
24 March 2015
Port retirement medical aid bene ts
Section 1( ) de nition of ‘gross income’ paragraphs (c), (f) and (i)
046
16 April 2015
Dividends distributed by foreign companies
Section 1 (1) de nition of ‘foreign dividend’
047
24 August 2015
Limitation of dividend exemption
Section 10 (1) (k) (i) (hh)
048
14 September 2015
Deductibility of expenditure incurred by a portfolio of a collective investment scheme in securities
Sections 1 (1) de nition of ‘income’, 11 (a) 23 (f) and 25BA
INCOME TAX ACT BINDING CLASS RULINGS (by section of IT Act)
BC RULING NO
DATE
NAME/SUBJECT
SECTION OF INCOME TAX ACT
003
12 May 2009
Distribution of an actuarial surplus to former members and active members of a retirement fund
Section 1 and paragraph 2C of the Second Schedule
022
27 July 2010
Potential double taxation of pro ts attributable to protected cell companies
Section 1 de nition of ‘company’ and section 9D
009
16 October 2009
Foreign share buy-backs
Section 1 de nition of ‘dividend’ and ‘foreign dividend’ and section 10 (1) (k) (ii) (dd)
044
2 May 2014
Repurchase of non-redeemable, non-participating preference shares
Note:
BCR 044 has been replaced on 20 May 2014 to provide for textual changes and additions to the original ruling for improved clarity - refer to paragraph 5 and third bullet point in paragraph 7
Section 1 (1), de nition of ‘equity share’; section 8E and paragraph 11 (2) (b) of the Eighth Schedule
(Also section 2(1) of the STT Act)
041
24 July 2013
Dividends distributed by a foreign company
Section 1 (1), de nition of ‘foreign dividend’
046
16 April 2015
Dividends distributed by foreign companies
Section 1 (1) de nition of ‘foreign dividend’
007
16 October 2009
Conversion of two public sector pension funds to a closed de ned bene t fund and a contribution fund respectively
Section 1 de nition of ‘gross income’ and ‘pension fund’ and paragraphs 1, 2 and 2A of the Second Schedule
008
16 October 2009
Tax consequences of proceeds of annuity policies purchased by employers to settle post-retirement medical aid subsidy obligations
Section 1 de nition of ‘gross income’ paragraph (i) and paragraphs 2 (i) and 12A of the Seventh Schedule
011
27 October 2009
Accrual of a conditional award and attendant tax implications
Section 1, paragraph (c) of the de nition of ‘gross income’
013
3 December 2009
Nature of dividend income when distribution by a discretionary trust to income bene ciaries by virtue of employment
Section 1 de nition of ‘gross income’ and sections 10 (1) (k) (i) and 25B
017
5 February 2010
Creation of a permanent establishment if a foreign partnership carries on business in South Africa
Section 1 de nition of ‘gross income’ and sections 10 (1) (h) and (k) (i) and paragraph 2 of the Eighth Schedule