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  • Interpretive assistance – early engagement

    When to request early engagement

    Request an early engagement discussion if you're considering seeking a private ruling, class ruling or administratively binding advice on the taxation outcome of a scheme.

    For issues associated with a scheme yet to be implemented, approach us as soon as practicable.

    For issues associated with an already implemented scheme, approach us as soon as practicable, after you identify an issue or an issue becomes apparent during your dealings with us.

    Interpretive assistance early engagement is available for large and medium business taxpayers in respect to income tax, resource rent tax, GST, FBT and withholding taxes. It is also available to large superannuation funds.

    The early engagement process

    • Our staff hold meetings with your staff.
    • We reach agreement with you on respective roles and responsibilities.
    • We negotiate with you and both commit to timeframes.
    • You provide a draft application for a ruling with full and true disclosure and relevant supporting information.
    • We discuss and agree on communication strategies.
    • We request more information and you provide it within agreed timeframes.
    • You lodge your final application for a ruling.

    How to contact us

    Send an email to

    We will contact you to discuss your request and outline the early engagement process.

    We will ask you to provide us timeframes, critical dates, details of the taxpayer and the scheme to which the proposed ruling application relates.

    You should also identify, at a high level, the tax issues you seek advice on. This enables us to engage the appropriate staff.

    When we receive this information, we will allocate the request to a case team. They will contact you to arrange an initial discussion or meeting.

    What to do if you have concerns

    If you're dissatisfied with the progress of your request, first raise your concerns with the case team.

    If you're still unhappy following discussions with the case team, email We will contact you to discuss the situation.

    Your final application

    At an agreed point in the early engagement process, make your final applications for a private ruling, class ruling or administratively binding advice.

    Highlight any changes to the arrangement you have not previously advised us of.

    We will then proceed to issue the ruling or advice within the agreed timeframes.

    Roles and responsibilities

    The ATO:

    • adopts a collaborative, open approach
    • ensures attendance of relevant experts at meetings
    • negotiates acceptable timeframe and commits to it
    • identifies any further information required
    • identifies further issues and notifies applicant
    • identifies where material facts need clarification
    • identifies any concerns
    • uses streamlined information gathering processes
    • implements agreed communication strategies.

    The applicant:

    • adopts a collaborative, open approach
    • provides sufficient detail upfront
    • ensures relevant personnel attend meetings
    • supports engagement protocols
    • lodges draft ruling request with full and true disclosure, and relevant supporting information
    • provides any requested information in agreed timeframes
    • ensures relevant personnel remain involved throughout the process
    • informs the ATO in a timely fashion of matters materially affecting the transaction or its timing.
    Last modified: 20 Jul 2016QC 49672