Advance tax rulings can be valuable to taxpayers since they provide comfort on how the tax framework applies to a particular transaction.
In October 2015 the Tax Department issued a circular setting out a new procedure for obtaining advance tax rulings. Following this, on the 26.04.2016, the Tax Department announced that administrative fees will now be payable for the issuance of advance rulings. Depending on whether the rulings requested are on an expedited basis or not, the administrative fee is set at €2,000 for expedited rulings and €1,000 for non-expedited. According to the Tax Department the new fees are applicable for requests filed from the 16.05.2016.
Taxpayers will also need to ensure that they are up to date with their tax return compliance obligations before requesting an advance tax ruling and be prepared to be more transparent with tax authorities as anonymous ruling requests have not be accepted from the 18.10.2015.
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The above should be used as a source of general information only. It is not intended to give a definitive statement of the law.