29 (or, in the case of a binding class ruling, in relation to the applicant or any class member); or B. the subject of any draft legislation; or C. pending before the courts. (2) In addition to the rejections set forth in subparagraph (1), the Commissioner may reject any application regarding or in respect of the following— (a) the application or interpretation of any general or specific anti-avoidance provision; or (b) an issue— (i) that is inherently or distinctly factual in nature; or (ii) in respect of which material facts cannot be established at the time of application; or (iii) the resolution of which would depend upon assumptions to be made regarding a future event or other matters which cannot be reasonably determined at the time of the application; or (iv) which would more appropriately dealt with by the competent authorities of the parties to the agreement for the avoidance of double taxation; or (v) which is the same as or substantially similar to an issue upon which the applicant has already received a ruling; or (vi) in which the tax treatment of the applicant is dependent upon the tax treatment of another party to the proposed transaction and that other party has not applied for a ruling; or (vii) in respect of a transaction that is part of another transaction which has a bearing on that issue and the details of that other transaction have not been disclosed; or (c) a matter the resolution of which would be unduly time-consuming or resourceconsuming or resource-intensive; (3) In addition to the rejections set forth in subparagraphs (1) and (2), the Commissioner-General may publish lists of issues in respect of which applications for advance tax rulings will not be accepted (4) If the Commissioner-General requests additional information in respect of or in connection with an application and the applicant fails or refuses to provide that information, the Commissioner- General may reject that application without any refund or rebate of any applicable fees. Binding effect of advance tax rulings 4.(1) The Commissioner-General must interpret or apply the Act in favour of the applicant or otherwise in accordance with the advance tax ruling given.

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