After a period of consultation, it has been decided that the Revenue should be empowered to issue legally-binding rulings in favour of taxpayers only where the relevant transaction has already taken place. This paper considers the reasons for having binding rulings, and argues that those reasons justify implementing pre- as well as post-transaction rulings. Additionally, it is contended that many of the more detailed aspects of the proposal warrant reconsideration in light of those underlying rationales.
Volume (Year): 18 (1997)
Issue (Month): 2 (May)
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