---
title: "Client information request and facts declaration for a private ruling application or return position"
url: "https://ailawframework.com/precedents/taxation/client-information-request-and-facts-declaration-for-ruling"
type: "precedent"
site: "AI Law Framework"
id: "a26-client-information-request-and-facts-declaration-for-ruling"
area_id: "A26"
kind: "letter"
ai_level: "yellow"
version: 1
task_ids: ["A26-A20260923-4", "A26-T1-R5"]
law_stated_as_at: "2026-10-18"
---

# 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…

Canonical page: https://ailawframework.com/precedents/taxation/client-information-request-and-facts-declaration-for-ruling  
Law stated as at: 2026-10-18

Site index for agents: https://ailawframework.com/llms.txt

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.

## Key facts

- Kind: Letter. A letter or email you adapt and send.
- Practice area: [Taxation](https://ailawframework.com/precedents/taxation.md)
- Jurisdictions: Australia
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-18
- Status: Maintained. Checked on 2026-10-18 against the authority it cites, for Australia.

## 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](https://ailawframework.com/practice/taxation.md#A26-A20260923-4)
- [Draft a private or product ruling application](https://ailawframework.com/practice/taxation/draft-a-private-or-product-ruling-application.md)

## 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

## Authorities

- [ATO, Applying for a private ruling (questions; all relevant facts, reasonably certain and not hypothetical; ruling does not apply if what is done differs substantially from what is described; arguments and references for tax professionals; supporting documents; agent declaration and the client’s written declaration that the information is true and correct)](https://www.ato.gov.au/about-ato/ato-advice-and-guidance/ato-advice-products-rulings/early-engagement-for-advice/applying-for-a-private-ruling)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/taxation/client-information-request-and-facts-declaration-for-ruling and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*