The Ministry of Finance has issued new guidance on section 89a of the General Tax Code (GTC), which has been the legal basis for advance ruling procedures since 2021.
Published on 26 June 2024, the guidance clarifies the application and interpretation of section 89a and will be included in the application decree on the General Tax Code. It covers all relevant aspects of advance ruling procedures, including the initiation of ruling procedures, the scope and content of applications, the binding effect of rulings, and related fees.
It replaces the information sheet on advance ruling procedures from 5 October 2006. However, the old information sheet will still apply to procedures where applications were submitted before 8 June, 2021.