What is
theRevenue Agency ruling

The ruling is a formal request that taxpayers submit to the Revenue Agency before taking any action that has tax implications, in order to obtain an official interpretation of a specific, personal case. The response, which is normally provided within 90 days, is binding on the Administration in that specific case and, if followed, protects against penalties and disputes.

  • Written opinion on complex tax cases.
  • Greater certainty before making important operational decisions.
  • Protection from penalties if you follow the response.

Eligibility

Who can benefit
from the Revenue Agency ruling

Special entities and entities

We assist public entities, foundations, withholding agents, and other entities that must correctly apply withholding taxes, substitute tax regimes, or complex anti-avoidance rules.

Startups and innovative companies

We assist startups, scale-ups, and innovative companies seeking preliminary clarification on new business models, digitization, platform economics, and taxation of intangible assets.

Professionals and consultants

We work with accountants, tax lawyers, and CFOs who want to structure technically sound applications for their clients, reducing interpretative uncertainty in sensitive cases.

Groups and multinational corporations

We support corporate groups and multinationals that require complex rulings on cross-border structures, transfer pricing, permanent establishments, and special regimes for significant investments.

SMEs and corporations

We support SMEs, corporations, and family businesses that want to clarify the application of uncertain tax rules on transactions, reorganizations, tax credits, and incentives.

Advantages

Advantages

Why choose Investria
for the Revenue Agency ruling

Specialized experience

We are familiar with the types of inquiries, updated practices, and typical critical issues involved in applications for tax breaks and credits.

Rigour and clarity

We structure questions, facts and solutions in a logical, comprehensive and readable way, even for management.

Ongoing support

We support you before, during, and after the consultation, assessing operational impacts, residual risks, and future regulatory updates.

We turn your tax questions into official answers, reducing uncertainty and putting the Agency on your side.

Our method

We follow a technical and
regulatory process that ensures fast turnaround times and
complete documentation.

We gather facts, documents, and objectives, verify that there is real regulatory uncertainty, and identify the type of ruling most suited to the question: ordinary, probative, anti-abuse, disapplication, or new investments.

We reconstruct the chronology of events, contracts, corporate structures, and tax calculations, preparing clear attachments that make the position presented to the Revenue Agency verifiable.

We examine laws, decrees, circulars, and responses to similar queries, evaluating alternative scenarios and risks of dispute for each possible interpretation.

We formulate the question, interpretative solution, and legal grounds, taking care of the formal requirements of the Revenue Agency, the Taxpayers' Charter, and relevant legislation, and verifying any contribution due.

We manage submission via certified email or electronic channels, monitor the 90-day deadline, suspensions, and possible effects of tacit consent in the event of no response.

We help you align internal procedures with the response, evaluate any subsequent queries, and monitor regulatory changes that may require adjustments.