Section 59

Withdrawal of a private ruling (TPA 2nd Sch Para 20)

(1) The Commissioner may, for reasonable cause, withdraw a private ruling, in whole or part, by written notice served on the applicant. 

(2) If legislation is made, or the Commissioner publishes a public ruling that is inconsistent with a private ruling, the private ruling shall be treated as withdrawn to the extent of the inconsistency. 

(3) The withdrawal of a private ruling, in whole or in part, shall have effect – 
(a) where subsection (1) applies, from the date specified in the notice of withdrawal; or 
(b) where subsection (2) applies, from the date of application of the inconsistent legislation or public ruling. 

(4) A private ruling which has been withdrawn shall – (a) continue to apply to a transaction commenced before the ruling was withdrawn; and (b) not apply to a transaction commenced after the ruling was withdrawn to the extent that the ruling is withdrawn.

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