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Call for comment: Draft binding general ruling on unbundling transactions

Wednesday, 26 November 2014   (0 Comments)
Posted by: Author: SARS
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Author: SARS

Section 46 of the Income Tax Act provides parties to an unbundling transaction with relief from various taxes that would otherwise become payable.

This BGR addresses the interpretation of the words "at the end of the day after that distribution” as used in section 46(3)(a)(v). 

Please click here to access the ruling. 

The SAIT will be making submissions to SARS on this matter. Kindly submit comments to by no later than 28 January 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.

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