108. Refusing an application for a private ruling

the Commissioner-General has already decided the question that is the subject of the application in any of the following:-

a notice of a tax assessment has been served on the applicant;

notice or other guidance issued by the

a ruling published under section 111 that is in force;

the application relates to a question that is the subject of a tax audit in relation to the applicant or an objection lodged by the applicant;

the application is frivolous or vexatious;

the transaction to which the application relates has not been carried out and there are reasonable grounds to believe that the transaction will not be carried out;

the applicant has not provided the tax official with sufficient information to make a private ruling;

in the opinion of the Commissioner-General, it would be unreasonable to comply with the application, having regard to the resources needed to comply with the application and any other matters the tax officer considers relevant; or

the making of the ruling involves the application of a tax avoidance provision.