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BPR 121: STC or Dividends Tax

17 September 2012   (0 Comments)
Posted by: SAIT Technical
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By SARS Legal & Policy

SARS recently issued Binding Private Ruling (BPR) 121. This ruling deals with the question as to whether a dividend to be paid toshareholders will be subject to secondary tax on companies or dividends tax.

The rulingwas requested on the interpretation and application of the provisions of –

  • section 64B(1), the definition of "declared”; and
  • section 64E(1) read with section 64D.

Please click here to download BPR 121.


Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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