A "binding private ruling" or "binding class ruling" applies to a person only if—
(a) |
the provision or provisions of the Act at issue are the subject of the "advance ruling"; |
(b) |
the person's set of facts or "transaction" are the same as the particular set of facts or "transaction" specified in the ruling; |
(c) |
the person's set of facts or "transaction" falls entirely within the effective period of the ruling; |
(d) |
any assumptions made or conditions imposed by SARS in connection with the validity of the ruling have been satisfied or carried out; |
(e) |
in the case of a "binding private ruling", the person is an "applicant" identified in the ruling; and |
(f) |
in the case of a "binding class ruling", the person is a "class member" identified in the ruling. |