Withdrawal of a private ruling
(1) The Commissioner may, for reasonable cause, withdraw a private ruling, in whole or part, by notifying the applicant in writing.(2) If a law is enacted or the Commissioner makes a public ruling that is inconsistent with a private ruling, the private ruling shall be withdrawn to the extent of the inconsistency of the private ruling with the law or the public ruling.
(3) The withdrawal of a private ruling, in whole or part, shall take effect from—
- (a) the date specified in the notice of withdrawal if subsection (1) applies; or
- (b) the date of the enactment of the inconsistent law or inconsistent public ruling if subsection (2) applies.
- (a) shall continue to apply to a transaction by the applicant that commenced before the ruling was withdrawn; and
- (b) shall not apply to a transaction of the applicant that commenced after the ruling was withdrawn to the extent the ruling is withdrawn.
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