The private rulings system provides an opportunity for taxpayers to obtain certainty on how the Commissioner will apply relevant provisions of the taxation laws to their specific circumstances or transaction. Private ruling applications can be made in respect of a range of matters including income tax, CGT, withholding tax, GST, franking tax and FBT.
A key consideration for practitioners advising their clients is whether or not applying for a private ruling is appropriate in the particular circumstances. Even where the prospects of success are good, the way in which a private ruling application is prepared and managed may greatly affect the outcome. It may mean the difference between obtaining a favourable ruling for your client and the client having to abandon/alter the proposed transaction or invoke their objection rights under Part IVC.