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Mr. Christophe J Waerzeggers and Mr. Cory Hillier
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.
Mr. Christophe J Waerzeggers and Mr. Cory Hillier

I. Overview 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. 1 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

Mr. Christophe J Waerzeggers and Mr. Cory Hillier

Front Matter Page IMF LEGAL DEPARTMENT Front Matter Page May 2016 Waerzeggers, Christophe and Cory Hillier, 2016, “Introducing an advance tax ruling (ATR) regime—Design considerations for achieving certainty and transparency,” Tax Law IMF Technical Note Volume 1, 2/2016, IMF Legal Department The authors acknowledge the benefit of the comments and thoughts of each of Michael Keen, Peter Barrand and Martin Grote of the IMF’s Fiscal Affairs Department This Tax Law Note was prepared by the tax counsels of the IMF’s Legal Department. This Tax Law Note

Mr. Christophe J Waerzeggers and Mr. Cory Hillier

Emerging Economies, OECD Publishing, Paris. Appendix B Sample Legislative Provisions for an Advance Ruling Regime Set out below is a sample set of provisions establishing an advance tax rulings regime. The provisions are general in nature and in the form of simplified sample provisions. Importantly, they do not take into account the individual circumstances of any particular tax system. The ultimate legal framework for the introduction or codification of an advance ruling regime in any given country would need to take into account the specific legal tradition

International Monetary Fund. Fiscal Affairs Dept.

medium L: Long-term Strengthening Tax Policy Process Amend the tax laws to provide that regulations on tax policy matters are made by the MOF S Regulations should be amended by making a subsequent amending regulation rather than by a tax ruling S Amend the TAA to provide that tax rulings are binding on MIRA but not on taxpayers S Tax rulings on tax policy matters should be made by the MOF with input from MIRA. However, such rulings could be formally issued by MIRA S Establish a TPU in the MOF and ensure institutional

International Monetary Fund. European Dept.

Decisions on Advanced Tax Rulings II. External Sector Assessment III. Implementation Status FSAP Update 2017 Recommendations Front Matter Page LUXEMBOURG STAFF REPORT FOR THE 2018 ARTICLE IV CONSULTATION—INFORMATIONAL ANNEX March 15, 2018 Prepared By European Department Contents FUND RELATIONS STATISTICAL ISSUES Front Matter Page LUXEMBOURG STAFF REPORT FOR THE 2018 ARTICLE IV CONSULTATION—SUPPLEMENTARY INFORMATION March 28, 2018 Prepared By European Department Front Matter Page Press