MEMBER 32 writes:
"Has anyone else experienced this? We lodged a private ruling application in relation to a proposed related party transaction and have asked for a ruling on both sides. One side of the transaction is straight-forward and non-contentious and the ATO provided a ruling with the expected answer. The other side of the transaction is the difficult part which we really wanted an answer to. The ATO declined to rule on the basis that the parties are 'not seriously contemplating the transaction'. The ATO clearly knows the parties are related (as originally one ruling application was lodged for both questions). Also, the ATO officer involved in both ruling requests was the same."