We may decline to give a private ruling in some circumstances, including if:
- we're considering, or have already considered, this issue for you – for example
- in an audit relating to the particular question
- where you have objected to a decision on the same matter
- where we have decided the matter when making an assessment
- we ask you to provide information we need and you don't provide it within a reasonable time
- we consider that making the ruling would prejudice or unduly restrict the administration of the law – for example
- your application is frivolous or vexatious
- you're not seriously contemplating the arrangement you describe
- making the ruling would not have any practical consequences for you – for example if the transaction in question occurred in the past and the amendment period has expired
- the Commissioner of Taxation chooses to exercise a particular power available under the law, rather than provide advice on how that power would be exercised
- we consider that the correctness of a private ruling will depend on certain assumptions and we choose not to make a ruling subject to those assumptions
- you decline to pay the cost of obtaining an accurate valuation
- the ruling application relates to the global and domestic minimum tax and the Commissioner of Taxation considers it would not be reasonable to comply with the application.
For more information see: