In a recently published judgment, the Supreme Tax Court decided that a fee may be charged for each individual request for binding advance ruling and that the number of requests is determined by the underlying facts as a single course of events. The judges further concluded that the fees for providing the requested information are not subject to the statute of limitations and the collection of these fees is not unconstitutional, even if the requested advance ruling is denied.
The Supreme Tax Court has held that an apparently definitive ruling by the tax office is binding for a future assessment unless its non-committal nature was apparent to the addressee.
The Supreme Tax Court has held that the value-based fee for a tax office ruling is to be based on immediate tax effects only, ignoring secondary consequences.
