BCR 025 replaced to provide for textual changes and to correct "exercise" to "vesting" in the first two bullet points in paragraph 7 in the section 8C formulae
This ruling deals with the income tax implications for the employees/senior executives within a group of companies in relation to their respective participation in a share option plan/share appreciation rights plan created by a holding company, and the appropriate apportionment formula that must be used to determine the amount to be included in the income of the employees/senior executives. The ruling also provides guidance on the employer’s obligation to withhold employees’ tax.
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.