Miscellaneous 2022

Private rulings: are they worth it?

Source: Taxation In Australia Journal Article

Published Date: 1 Jul 2022


This article seeks to describe a structured approach, with reference to the law and relevant decisions, which may be used when trying to decide whether it is worthwhile to apply for a private ruling. The framework suggested is that which is generally used in choosing consumer products. The article suggests that the decision must be made by reference to the taxpayer's corporate attitude to tax risk, and the other approaches available for achieving the desired level of certainty on the tax risk associated with a particular issue. Depending on the circumstances, other approaches may be preferred. Rulings, however, offer an opportunity to understand the Commissioner's reaction to a situation and, through engagement, achieve a positive response. They require particular care in drafting, and care in the evaluation of the response.

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Miscellaneous 2022

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