31 (b) in the case of a binding class ruling, the ruling applies to a person only if that person is either the applicant identified in the ruling or a class member identified in the ruling Rulings rendered void due to fraud, misrepresentation, etc. 7.(1) A binding private ruling or a binding class ruling is nullified under any of the following circumstances— (a) the facts stated in the application regarding the proposed transaction are materially different from the transaction actually carried out; or (b) there is a misrepresentation or wilful nondisclosure of a material fact; or (c) any condition or assumption stipulated by the Commissioner-General as a condition of the issue or binding effect of the ruling is not satisfied or carried out. (2) For purposes of this paragraph, a fact is considered material if it would have resulted in a different ruling had the Commissioner-General been aware of it when the original ruling was made. Impact of subsequent changes in tax law 8(1) An advance tax ruling ceases to be effective upon the occurrence of any of the following circumstances— (a) if the provision of the Act that was the subject of the advance tax ruling is repealed or amended, the advance tax ruling will cease to be effective from the date such repeal or amendment is effective; (b) if a court overturns or modifies an interpretation of the Act on which the advance tax ruling is based, the advance tax ruling will cease to be effective from the date of the court’s judgment unless— (i) the decision is under appeal; or (ii) the decision is fact-specific and the general interpretation upon which the advance tax ruling was based is unaffected; or (iii) the reference to the interpretation upon which the advance tax ruling was based was obiter dicta. (2) An advance tax ruling ceases to be effective immediately upon the occurrence of the circumstances described in subparagraph (1), whether or not the Commissioner-General publishes a notice of withdrawal or modification. Withdrawal or modification 9.(1) Subject to this paragraph, the Commissioner-General may withdraw or modify an advance tax ruling at any time. (2) Notification of the withdrawal or modification of an advance tax ruling must be communicated in such a manner as the Commissioner-General considers will notify the persons affected by it and must include the following information— (a) the title or number of the advance tax ruling being withdrawn or modified; and

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