South Africa Tax Agency Clarifies Tax Implications of Specified Transfer of Reinsurance Business

The South African Revenue Service Nov. 13 issued Binding Private Ruling No. BPR 416, clarifying the tax implications of a reinsurance business transfer from a resident reinsurer to a local branch of a nonresident company. The taxpayers consisted of a South African private company and the permanent establishment (PE) of a nonresident company (Company A) holding all the issued share capital in the private company. The private company intended to implement a restructuring by transferring its entire business, consisting of all its assets and liabilities, to Company A. Upon review, the Tax Agency clarified that: 1) only the transfer of ...