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Public rulings provide greater certainty on the application of tax law to:

  • allow taxpayers to enter into commercial transactions with confidence, and
  • foster taxpayers' compliance with their legal obligations.

Public rulings are the Commissioner's formally binding interpretations of the tax law, interpretation statements and guidelines. Issues may be brought to the Tax Counsel Office when there is doubt or different views about how the law should apply to particular arrangements or matters. Completed public rulings are published and then become the Commissioner's view on that matter.

Public rulings, interpretation statements and guidelines are available to browse and download on our Tax Technical website.

Tax Technical

The TCO communicates its interpretations to both external customers and Inland Revenue staff by:
  • publishing public rulings and interpretation statements and guidelines here on the website and in the Tax Information Bulletin
  • supplying copies of the above to interested parties on request, mainly by email.

It is important that binding rulings, which bind the Commissioner for the period of their application, are technically correct and in accordance with the tax Acts and relevant case law. Staff members who are usually qualified solicitors, must thoroughly research the issues. Draft public rulings go through a consultation process that gives Inland Revenue groups and external interested parties an opportunity to comment

Public rulings work programme

Towards the end of each financial year (30 June), a draft programme of priority work is prepared for the following year. The criteria for inclusion in the programme are based on such factors as the importance of the issues involved, the level of uncertainty/ambiguity, the number of taxpayers potentially affected, the need to resolve existing issues, and the potential revenue implications. The draft is consulted on with key stakeholders.

This has the advantage of permitting the TCO to plan in advance its work commitments and better ensure that it produces timely and relevant items.

Our work programmes - Tax Technical

Public statements customer feedback surveys

Every 3 years we run an online customer survey, to explore ways of improving our public items and our consultation and publication process.

The next public statements survey will be held in 2021.