SARS-General3

Binding Class Ruling on hybrid equity interest or third party backed share (BCR 081)

8 September 2022

Income Tax Act, 1962 – Binding Class Ruling: BCR 081

Binding Class Ruling 081 relates to Section 8E and 8EA on hybrid equity interest or third-party backed share. This ruling determines whether a participatory interest held by a class member in a collective investment scheme (CIS) in securities constitutes a “hybrid equity instrument” as defined in section 8E or a “third-party backed share” as defined in section 8EA.

This binding class ruling is valid for a period of five years from 4 May 2022. You can read the the ruling here.

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