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.
See alsoWe may decline to give you a private ruling in some circumstances.