Priority private binding rulings - whether to apply for one or not?
03 Aug 05 |
WEEKLY TAX BULLETIN
Issue: No 31 22 July 2005
Pages: pp. 1198-1201
In May this year, the Tax Office, issued Practice Statement Law Administration PS LA 2005/10, Priority private binding rulings. This policy statement sets out when the Tax Office will give a private binding ruling application priority, and how this priority is obtained. Broadly, priority is given where the ruling is for a proposed transaction, the issues are significant and there is some urgency.
In the article, the authors discuss why taxpayers may or may not wish to apply for a private ruling in regard to the tax treatment of past events, and we examine the implications of the policy statement.
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Daniel McInerney, CTA, is a taxation
barrister at the Victorian Bar known
for his strong technical and advisory
knowledge. He has appeared in a
number of complex taxation cases
addressing issues such as transfer
pricing, international corporate
structuring, consolidations and Part IVA.
Daniel works closely with Australia’s
leading tax silks, multinational,
mining services and financial services
companies. He has an extensive
advisory practice in relation to
structuring as well as settling taxation
disputes with the ATO. Daniel is regularly
named as a leading junior counsel
in Doyles Guide’s list of Leading Tax
- Current at
25 June 2018
Michael is a Partner with PricewaterhouseCoopers Legal and is the leader of the PricwaterhouseCoopers Legal Tax Controversy Practice. Michael was formerly an ATO Deputy Chief Tax Counsel and Deputy Australian Government Solicitor.
- Current at
26 July 2006