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Introducing an Advance Tax Ruling (ATR) Regime
Author:
Mr. Christophe J Waerzeggers
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and
Mr. Cory Hillier
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Series:
Tax Law Technical Note
Volume/Issue:
Volume 2016: Issue 002
Language:
English
Publication Date:
31 May 2016
DOI:
https://doi.org/10.5089/9781513511610.008
ISBN:
9781513511610
ISSN:
2523-5753
Pages:
14
Keywords:
TLT; ruling; tax ruling; tax; authority; taxpayer; advance; tax authority; rulings system; ruling application; ruling regime; advance ruling; ruling procedure; Tax law; Legal support in revenue administration; Tax administration core functions; Africa
Legal-disclaimer:
This Tax Law Note should not be reported as representing the views of the IMF. The views expressed in this Tax Law Note are those of the authors and do not necessarily represent those of the IMF or IMF policy.
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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.
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Cover Tax Law Technical Note
Tax Law Technical Note
ISSN:
2523-5753
Publisher:
International Monetary Fund