This ruling determines the tax consequences for the Applicants following the proposed distribution by a holding company of shares in an intermediate holding company to its shareholders in terms of the de-grouping rules in section 45(4).
Source: SARS
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- (7)Capital Gains Tax
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- (10)Compliance
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- (15)Customs and Excise
- (2)Deceased Estate
- (1)Deductions Pre-trade and prepaid expenses
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- (4)SARS Issues
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BINDING PRIVATE RULING: BPR 388 - Application of the de-grouping rule following previous intra-group transactions under section 45
- Corporate Tax
- SARS
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