SARS Binding Private Ruling 279

Date: 14 September 2017

Act: Income Tax Act 58 of 1962

Summary: This ruling determines that the participation exemption from capital gains tax (CGT) is available in relation to the disposal of assets by a controlled foreign company (CFC) since the parties are not connected persons at the time of the proposed transaction, albeit that such a relationship is created by the transaction.

This binding private ruling is valid for a period of five years from the date of this ruling.

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