The South Africa Revenue Service has published Binding Private Ruling (BPR) 279 on the capital gains tax participation exemption in relation to controlled foreign companies (CFC), which includes the condition that the parties to a transaction are not connected persons. The ruling concerns a resident of South Africa (the applicant) that wholly owns a foreign subsidiary (the co-applicant - CFC), which wholly owns two foreign subsidiaries (companies A and B). The applicant acts as a principal investor in multinational development projects and is planning to merge its investments with a foreign principal investor (the counterparty). The transactions will involve making...