A Newly-Regulated Use Of Advance Rulings

Tax assessment commissions are now required to take advance rulings into consideration in their judgements.

As per the new regulations, tax assessment commissions are now required to take advance rulings issued to other taxpayers into consideration. In this regard, an advance ruling is required to be considered if, (i) it addresses the relevant regulations effective as of the tax period to which the assessment is related and (ii) it has been issued under Article 413 of the Tax Procedural Law (i.e., following the amendment effective as of 1 August 2010).

Any tax relief provided to taxpayers through advance rulings that they request, if any, should still be binding for the local tax administration irrespective of the date of issuance of such rulings, as long as the applicable conditions and regulations have remained unchanged.