Letter · Taxation
Client information request and facts declaration for a private ruling application or return position
Letter asking a client for the facts and documents needed for a private ruling application (or a contentious return position), with a facts checklist, a supporting documents list, and the written declaration an agent must hold that the information is true and correct.
- Kind
- Letter. A letter or email you adapt and send.
- Where it applies
- Australia
- AI use
- Yellow AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at
- 18 October 2026
- Status
- Maintained. Checked on 18 October 2026 against the authority it cites, for Australia.
- Version
- 1
- Source
- Written for this library
When to use it
Use at the start of a private ruling engagement, or before taking a return position the firm wants documented, to collect the complete and reasonably certain facts the ATO requires. The ruling application itself is prepared with the completion guide in this library once the facts are settled.
Used for these tasks
- Prepare an information request for a return position or ruling
- Draft a private or product ruling application
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
AI may tailor the checklist to the transaction from the engagement notes and track what the client has supplied; the adviser decides which facts are relevant and settles the questions, and the client signs the declaration only after checking the facts themselves.
AI may
- Turn the engagement notes into a tailored facts checklist and documents list for the transaction
- Track which items have been received and list gaps, inconsistencies and dates that do not match across documents
- Prepare a first draft of the facts statement from the documents received, with each fact referenced to its source, for the adviser to check
AI must not
- Must not fill a fact the client has not given or the documents do not show, or present a proposed step as certain when it is not
- Must not frame the ruling questions or the arguments; those are the adviser’s
- Must not process tax file numbers or the client’s financial records outside an approved environment
The lawyer checks
- Every fact in the facts statement is traceable to the client or a document, and proposed steps are reasonably certain rather than hypothetical
- The facts cover everything relevant to the questions, including related parties, prior rulings and any steps already taken
- The client has signed the declaration that the information is true and correct, and the firm holds it before the application is lodged
- The client understands that the ruling will not apply if what is done differs substantially from what is described
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
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- Objection to an ATO assessment or decision: completion guide and grounds structure
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- Client notice on AI use with tax records and tax file numbers