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Priority private binding rulings - whether to apply for one or not?

Publication date: 03 Aug 05 | Source: 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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Author profiles

Daniel McInerney CTA
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 Barristers. - Current at 25 June 2018
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Michael Bersten
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
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