Section 67

Making a private ruling 

(1) If the Commissioner makes a private ruling, the Commissioner shall notify the applicant of the ruling in writing.

(2) The Commissioner may make a private ruling based on assumptions about a future event or any other appropriate ground.

(3) A private ruling shall state that it is a private ruling, set out the question ruled on, and identify–

• (a) the taxpayer; 
• (b) the tax law relevant to the private ruling; 
• (c) the reporting period to which the ruling applies; 
• (d) the transaction to which the ruling relates; and
• (e) any assumptions on which the ruling is based. 

(4) A private ruling shall take effect when the applicant is served with written notice of the ruling and the ruling shall remain in force until it is withdrawn.

No. 40 of 2013
(5) A private ruling shall set out the Commissioner’s opinion on the question raised in the ruling and is not a decision of the Commissioner for the purposes of this Act or the Tax Appeals Tribunal Act, 2013.

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