request additional information or clarification in relation to the application. The ruling application should go through an appropriate internal review process (e.g. two level review process) before making a decision to grant a ruling.
Notice of proposed ruling . Following the completion of the review process, the taxpayer will be notified of the proposed outcome of the ruling (i.e. favorable or unfavorable):
If the proposed ruling is favorable, then the taxpayer will be provided with a draftruling which it must carefully review, particularly the description of
Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries. Increasingly, many non-OECD countries are also offering advance tax rulings. An advance tax ruling regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority. However, there are also inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported. This Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.