The Rulings Directorate has a services standard of providing an ATR within about 4 ¼ months, excluding delays for taxpayer information

Some points made by Costa Dimitrakopoulos (the new Director General) and Lori Carruthers on the Directorate's ATR service include:

• The Directorate’s services standard is for 85% of Advance Tax Ruling requests to be resolved within 90 business days of receipt of all essential information (or, it would appear from other remarks, within 90 business days of receipt of the request, but excluding the days that the ball is in the representative’s court to provide missing information). The Directorate met its service standard in 2015-16 (at 87%), but fell short this last year (at 78%). (90 business days equates to about 4 ¼ months.)
• Over the last five years, the Directorate has been experiencing a steady decline in ATRs except for an unexpected upswing in 2015-2016. In 2012-2013, it had about 175, and in 2016-2017, about 129.
• The Directorate provides input on draft legislation to Finance during drafting sessions.
• The Directorate’s most significant discovery when it reviewed the ATR programs of other countries was that some countries will not give ATRs on their anti-avoidance rules, and this became a significant topic of discussion in the Directorate’s external and internal consultations. The upshot was that the Directorate will continue entertaining ATR requests on the anti-avoidance rules including the impending MLI principal purpose test.
• External consultations revealed that the pre-rulings consultation service was not being used very much, primarily because it requires much of the same information as an ATR request, and also because it is not available on a no-names basis.
• The next revision to the Information Circular will include a draft template for ruling requests and also guidelines respecting rulings on questions of fact, and refusals to rule where there is no uncertainty.

Neal Armstrong. 20 November 2017 CTF Conference - Costa Dimitrakopoulos and Lori Carruthers on "Advance Tax Rulings - 2017 and Beyond."