Introducing an Advance Tax Ruling (ATR) Regime

Tax Law Technical Note, May 31, 2016

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Advance tax rulings are a common feature of mature tax systems.
Countries with established ruling practices explicitly noted: the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa.
Taxpayers can obtain an advance tax ruling in nearly all OECD member countries.
Increasingly, many non-OECD countries are also offering advance tax rulings.
The ATR regime seeks to promote clarity and consistency regarding the application of the tax law for both taxpayers and the tax authority.
The Tax Law IMF Technical Note focuses on designing an advance tax ruling regime in the nature of private tax rulings.
There are inherent risks associated with the proliferation of granting confidential advance tax rulings which are not published or otherwise reported.

Purpose of ATRs:
- Promote clarity and consistency in the application of tax law.
- Provide guidance to both taxpayers and the tax authority.
Prevalence:
- Established ruling practices in the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa.
- Available in nearly all OECD member countries and increasingly in non-OECD countries.
Risks:
- Proliferation of confidential advance tax rulings that are not published or otherwise reported poses inherent risks.

Content based on "Introducing an Advance Tax Ruling (ATR) Regime", Tax Law Technical Note 2016, 002, IMF, May 31, 2016.