27 “transaction” means any transaction, deal, business, arrangement, operation or scheme, and includes a series of transactions. Application for advance tax ruling 2.(1) Subject to the minimum requirements set forth in subparagraph (2), an application an advance tax ruling must be made in such manner and in such form as the Commissioner-General may prescribe, and be accompanied by the fee prescribed in terms of section 90, if any. (2) An application must state the following minimum information— (a) applicant’s name, postal address and telephone number; and (b) the name, postal address and telephone number of the applicant’s representative, if any; and (c) a complete description of the proposed transaction in respect of which the ruling is sought; and (d) a complete description of the impact the proposed transaction may have upon the tax liability of the applicant or, where relevant, any connected person in relation to the applicant, including any and all relevant information regarding the financial or tax implications of the proposed transaction; and (e) a complete description of any transactions entered into by the applicant prior to submitting the application or that may be taken after the completion of the proposed transaction which may have a bearing on the tax consequences of the proposed transaction or may be considered to be part of a series of transactions involving the proposed transaction; and (f) the proposed ruling being sought; and (g) a citation of the relevant statutory provisions or issues; and (h) the reasons why the applicant believes that the proposed ruling should be made; and (i) a statement of the applicant’s interpretation of the relevant statutory provisions or issues, as well as an analysis of any relevant authorities either considered by the applicant or of which the applicant is aware, whether those authorities support or are contrary to the proposed ruling being sought; and (j) a statement that, to the best of the applicant’s knowledge, the same or substantially the same or a substantially similar issue upon which a ruling is sought is not the subject of an audit, examination, investigation, ruling application, objection and appeal, or other proceeding currently before the Commissioner-General or the courts involving the applicant or a connected person in relation to the applicant; and (k) a draft version of the binding private ruling or binding class ruling to be issued; and