Print Page   |   Report Abuse
News & Press: Corporate Tax

BCR 032: Distribution of certain shares to certain foreign shareholders as a result of restructuring

29 February 2012   (0 Comments)
Posted by: Philip Kotze
Share |

Binding Class Ruling 032

Section 46 of the Income Tax Act

Section 8 of the STT Act

SUBJECT : DISTRIBUTION OF CERTAIN SHARES TO CERTAINFOREIGN SHAREHOLDERS AS A RESULT OFRESTRUCTURING

Summary

This ruling deals with the tax consequences that will arise from

-the distribution of shares to shareholders in terms of anunbundling transaction; and

- the disposal of certain of the shares available for distribution interms of the unbundling transaction on behalf of certain foreign shareholders as well as the distribution of the net proceeds thereof to such foreign shareholders.

This ruling also deals with the question as to whether the transfer of theshares to shareholders will be exempt from securities transfer tax.

To access the ruling, click here


WHY REGISTER WITH SAIT?

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.

MINIMUM REQUIREMENTS TO REGISTER

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.

Membership Management Software Powered by YourMembership  ::  Legal