Abstract

Although an application for individual tax rulings is very common and popular instrument for taxpayers, their real value in case of potential dispute with tax authorities is not so obvious. The overview of issued tax ruling practice leads to conclusions that there are situations in which applicants abuse individual tax rulings and indicates cases when application for a tax ruling seems to be useless.

Individual tax rulings do not entail with granting, confirmation or approval rights and obligations resulting from tax law, they are binding neither for tax authorities nor for taxpayers. In respect of individual tax ruling, one should definitely resign from colloquially used term “binding tax ruling” because it may mislead taxpayers (tax advisor’s clients) as to the effect of received tax rulings.