Request a private ruling
We provide private rulings to help you understand how we interpret legislation we administer, specific to your situation.
We provide private rulings on request once you identify a tax technical or legislative issue which makes you uncertain of your liability. A private ruling may be issued to help you pay the correct amount of tax.
You (or your representative) can request a private ruling on your own or with others involved in your arrangement or transaction. When you request a private ruling, you authorise us to access information or contact third parties as required.
A private ruling will only be issued if:
- you have identified a tax-technical and/or legislative issue requiring clarification
- we have not dealt with the issue in one of our public rulings
- all requirements in Step 1 (below) have been met.
A private ruling will not be issued:
- to provide you with legal advice – if your situation involves complex and technical legislation, you need to seek independent legal advice before requesting a ruling
- based on a hypothetical scenario or a general opinion on how the legislation should work
- to evaluate options and advise on options resulting in the lowest tax or duty
- to engage in an iterative process if you previously received an unfavourable decision and are requesting another ruling for a similar, although modified, situation
- to confirm that all evidentiary requirements for an exemption or refund are met.
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Prepare the written requirements
Your request must be in a written submission, and:
- explain why a private ruling is required
- identify all parties involved by name and address
- outline all material facts in relation to the transaction or arrangement which you are seeking the ruling for
- describe the legislation and the issue in question
- state how you interpret the key provisions, your rationale (including arguments for and against) and any relevant case law
- permit the Commissioner of State Revenue to access information or contact third parties as required.
Read more information on private rulings.
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Gather supporting documents
Prepare copies of any documents that support your request. If relevant, include a diagram of the transaction or corporate structure.
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Prepare a signed statement
Where your request for a private ruling concerns a proposed course of action, you must include a statement signed by you and any other joint applicants. This statement should contain:
- an estimated completion date for the proposed course of action
- a declaration by you and any other relevant parties stating that there is a genuine intention to proceed with the proposed course of action depending on the ruling given. Also, confirm that you have disclosed all relevant facts.
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Lodge your submission
Please use the subject line 'Request for private ruling' and include all supporting documents.
Where you send your private ruling depends on the issue it relates to.
Requests for a private ruling on the application of the Duties Act 2000 landholder or lease provisions should be sent to:
- Email: landholder@sro.vic.gov.au
- Mail:
Landholder Acquisitions Branch
State Revenue Office
GPO Box 1641
Melbourne VIC 3001
All other requests for private rulings should be sent to:
- Email: technicaladvice@sro.vic.gov.au
- Mail:
Technical Advice and Review Branch
State Revenue Office
GPO Box 1641
Melbourne VIC 3001
Next Steps
We aim to issue private rulings within 90 days of receiving a submission. The time it takes depends on:
- the complexity of the transaction or arrangement it relates to
- the nature of the legislation involved, and
- whether more information is needed to support your claim.
A private ruling only applies to the customer it is given to and to the facts presented. Other customers cannot rely on private rulings as a precedent. Likewise, a tax practitioner cannot rely on a private ruling for one customer as a precedent for another client.
If the facts or circumstances you provided change after we issue the private ruling, please contact us. You or your representative must check if the private ruling still applies.
A qualified private ruling applies as long as the conditions stated in the ruling remain valid. The onus rests with the customer to monitor the continuing validity of the ruling.
Last modified: 19 March 2025
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