The Binding General Ruling (BRG) No. 30 determines the allocation of direct and indirect operating expenses within and between the funds that are required to be established by insurers.
This Binding General Ruling (BGR) No.30 determines the allocation of direct and indirect operating expenses within and between the funds that are required to be established by insurers under section 29A and the subsequent deductibility of such operating expenses, and the deductibility of expenses against inter fund transfers.
Expenses have to be allocated in a manner consistent to which the business is conducted. Expenses and associated costs are allocated to a policyholder fund or risk policy fund if the expense is incurred to produce excess assets to be transferred from a policyholder fund to a corporate fund. When expenses are allocated to the corporate fund they are not regarded to be incurred with a view to obtaining an abovementioned inter fund transfer.
Expenses which do not directly relate to a specific fund (such as operational overhead costs and general marketing costs, for example) are however generally treated inconsistently by taxpayers.
The extent to which expenses in policyholder funds are deductible are
limited. Expenses in the corporate fund are however not subject to expense
relief. Facts and circumstances dictate to which fund expenses are attributable, for which a (direct) causal link is required.
In view of the inconsistent treatment of expenses within and between the
separate funds of an insurer, BGR 30 has been issued to clarify the treatment of expenses that is accepted  by SARS:
Period for which this ruling is valid:
This BGR applies from 7 January 2016 until it is withdrawn, amended or the relevant legislation is amended.
 Section 29A(7) of the Income Tax Act.
 Section 29A(12) of the Income Tax Act.
 Section 29A(11) of the Income Tax Act.
 For purposes of section 29A(11) and section 29A(12) of the Income Tax Act.
 In terms of section 29A(11)(a)(i) of the Income Tax Act.
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