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(l) a description of the information that the applicant believes should be deleted
from the final ruling before the publication of the ruling in order to protect the
applicant’s confidentiality; and
(m) the applicant’s consent to the publication of the ruling by the CommissionerGeneral.
(3) In addition to the minimum information required by subparagraph (2), an
application for a binding class ruling must also state the following minimum information—
(a) a description of the class members concerned; and
(b) the impact the proposed transaction may have upon the liability of the class
members or, where relevant, any connected person in relation to the applicant or
to any class member.
(4) The Commissioner-General may request additional from an applicant at any time.
Cases where applications for advance tax ruling must be rejected
3.(1) Notwithstanding the foregoing provisions, the Commissioner-General shall not
accept an application for advance tax ruling in any of the following circumstances—
(a) where the application requests or requires the rendering of an opinion,
conclusion or determination regarding or in respect of any of the following—
(i) the market value of an asset; or
(ii) the application or interpretation of the laws of a foreign country; or
(iii) the pricing of goods or services supplied by or rendered to a connected
person in relation to the applicant (or to a class member in the case of an
application for a binding class ruling); or
(iv) the constitutionality of any tax law; or
(v) a proposed transaction that is hypothetical or not seriously contemplated;
(b) where the application relates to the duty of an employer to determine whether a
person is a casual, part-time or full-time employee, or an independent contractor;
or
(c) where the application is submitted for academic purposes; or
(d) where the application presents, contains, or raises—
(i) a frivolous or vexatious issue; or
(ii) alternative courses of action by the applicant (or requests or requires the
rendering of an opinion, conclusion or determination regarding such
alternative courses of action); or
(iii) an issue that is the same as or substantially similar to an issue that is—
A. the subject of an audit, examination, investigation or other
proceeding by the Commissioner-General involving the applicant
Select target paragraph3
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