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(1) The Commissioner-General may refuse an application for a private or class ruling if

(a) in the case of a private ruling

(i) the arrangement has already been the subject of a tax decision; or

(ii) the Commissioner-General has commenced an investigation of the tax affairs of the applicant in respect of the arrangement or, before the application, has notified the applicant in writing of an intention to do so;

(b) the Commissioner-General is of the opinion that an existing practice note adequately covers the arrangement;

(c) the application is frivolous or vexatious;

(d) the arrangement has not been carried out and there are reasonable grounds to believe that the arrangement will not be carried out;

(e) the applicant has not provided the Commissioner-General with sufficient information to make a ruling;

(f) the applicant for the ruling has not paid the fee for the ruling; or

(g) in the opinion of the Commissioner-General, it would be unreasonable to comply with the application having regard to the resources needed to comply and any other matters the Commissioner-General considers relevant.

(2) Where the Commissioner-General refuses an application for a private or class ruling, the Commissioner-General shall, within thirty days of the decision, serve the applicant with a written notice of the refusal stating the reason for the refusal.