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​BPR 204: Definition of "disposal" for asset-for-share and amalgamation transactions

26 August 2015   (0 Comments)
Posted by: Author: SARS
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Author: SARS

This ruling deals with –

  • the conversion of a portfolio of a collective investment scheme in properties, currently listed as a Real Estate Investment Trust (REIT) on the JSE, to a corporate REIT. Prior to the conversion, immovable property will be transferred to a property company;
  • whether the date of transfer of ownership in immovable property in the Deeds Office into the name of the property company impacts on the time of disposal of that immovable property for purposes of the asset-for-share transaction and the amalgamation transaction; and 
  • whether the declaration date of a distribution, as opposed to the date of payment, is the relevant time for determining if the distribution is a "qualifying distribution” under section 25BB. 

Please click here to view ruling (24 August 2015). 


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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