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BPR: Headquarter companies: Acquisitions of shares and loans

23 February 2016   (0 Comments)
Posted by: Author: SARS
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Author: SARS

This ruling (BPR 223) determines the income tax consequences resulting from the acquisition by a company, that is a resident of South Africa, of shares in and loans of a foreign company for purposes of the headquarter company regime.

Please click here to view ruling.



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.

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