This presentation will arrive at an answer to the framing question by considering the legislative framework and case law in order to understand the scope of the Private Ruling system, its uses and limitations.
This presentation covers:
- Division 359 - what is a private ruling, how do you get one, what is the effect of a private ruling, what can you do if you are dissatisfied with one, other specific references to the private rulings in the Act
- ATO guidance - ATO public statements on private rulings, relationship to the law
- Case law - issues that have been litigated, what the cases tell us about the limitations and benefits of the private rulings system
- Brief comparison of the Private Ruling system with other approaches to issue clarification
- Concluding recommendations