Ruling Request Assistance

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The ruling request assistance service is designed to minimize various tax risks by obtaining a written ruling from the tax authorities setting forth the applicability of statutory provisions of any tax or charge administered by the tax authorities to a specific set of facts.
Obtaining a ruling minimizes risks from uncertainties of a prospective business so as to promote the efficiency and confidence of a management decision.
If a ruling is obtained to uphold a client issue, it will ensure that refund of a certain amount of taxes paid would be obtained through the request for re-examination of assessment and tax appeal.

Samil PwC professionals are regularly involved in tax risk analysis, pre-audit tax reviews, tax appeals, mergers and acquisitions, split-offs, reorganizations and other business advisory consultations.
With our experience, we can assist clients in formulating the most appropriate strategy to obtain a favorable ruling on the applicability of certain tax law provisions.

Our ruling request assistance services include:
 

  • Identification tax issues that require a ruling by the relevant tax authorities.
  • Evaluation and quantification of tax effect involving the identified tax issues.
  • Development of a rationale that can provide a basis to obtain a favorable ruling.
  • Assistance with the drafting of the ruling requests and explanations of facts and issues to the relevant authorities.