Rulings and Technical Interpretations

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A company can request a ruling or technical interpretation on matters of uncertainty

Obtaining a Ruling

If you require clarification of complex issues, it may be appropriate to request that the BC Ministry of Finance provide an advance ruling or a technical interpretation. The Ministry will issue, at no cost, written advance rulings and technical interpretations to explain technical matters relating to the International Business Activity Act (IBAA).

For information purposes, the Ministry has made past rulings and technical interpretations available through their website.

Advance Rulings

An advance ruling is a written statement the Ministry provides on proposed transactions that sets out the Branch’s position on how the relevant provisions of the legislation apply to a clearly defined fact situation of the claimant.
Receiving an advance ruling enables claimants to decide on a particular course of action by providing certainty with respect to the implications of the IBAA to proposed business transactions. Accordingly, advance rulings are only given on proposed transactions which are seriously contemplated and are not of a hypothetical nature.
Advance rulings cannot be provided on issues already under review or audit.
Advance rulings are based on a review of the relevant facts and proposed transactions disclosed to the Ministry. The rulings given are provided on the basis that the facts are correct and complete and that the proposed transactions are carried out in the manner disclosed. The advance ruling is no longer valid if the legislation on which the ruling is based is subsequently amended or a court decision changes the interpretation of the law upon which the ruling was based.

Technical Interpretations

A technical interpretation provides the Ministry's view of how the legislation would apply to a generic fact situation. Technical interpretations generally apply to hypothetical fact situations and the interpretations are not binding.
Technical interpretations are for general guidance only and do not imply any assurance over the treatment of the specific transactions involved.
All written requests for an advance ruling or technical interpretation will receive a prompt acknowledgement. The acknowledgement will provide the name of a contact who can provide updates on the progress of the ruling or interpretation.

Further details on the International Business (IB) program can be found in Bulletin IFA 001, International Financial Activity Overview .

The IB program is administered by the BC Ministry of Finance. For more information regarding the legislation or provincial registration, please visit their website. The information on this website is provided for convenience and guidance only and is not a replacement for the legislation. Businesses considering accessing the benefits under the program should consult with their professional advisors on the applicability of the legislation to their particular circumstances.

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