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