Description: New Zealand's list of participating jurisdictions made by determination for the purposes of the CRS applied standard (CRS) and requirements under Part 11B of the Tax Administration Act 1994 on the 21st of June 2017 will be amended with effect from the 1st of April 2018.

Description: The Revenue Alert sets out some of the factors that would cause tax avoidance concerns. In general, transactions where a person sells shares in one company to another company in which they have a significant interest in, then depending on the way the transaction has been structured, section BG 1 (or GB 1) may apply.

Description: This ruling covers the reclassification of two classes of shares (Co-operative Control Shares and Investment Shares) into a single, continuing class of shares (Ordinary Shares) listed on the New Zealand Alternative Market Exchange (NZAX).

Description: This ruling applies to a BNZ product called TotalMoney, a package of accounts and loans offered to customers. TotalMoney allows customers to group or aggregate accounts for the purposes of either 'pooling' or 'offsetting' the account balances.

Description: This item considers when an arrangement (the revised arrangement) will be 'materially different' from the arrangement identified in a private or product ruling for the purpose of ss 91EB(2)(a) and 91FB(2)(a) of the Tax Administration Act 1994. It concludes that the revised arrangement is 'materially different' if, in relation to a tax type, the difference between the revised arrangement and the arrangement identified in the ruling is capable of affecting the tax outcome referred to in the ruling. Whether the revised arrangement is materially different from the arrangement identified in the ruling will depend on the facts and circumstances of the case.

Description: Share purchase scheme account maintained by CRS Nominees Limited is an excluded account for the purposes of the CRS applied standard and requirements under Part 11B of the Tax Administration Act 1994.

Description: This determination relates to a funding transaction involving the issue of Notes by Bank to Group Member pursuant to a Deed Poll. The Notes will contain a conversion mechanism to allow them to be recognised as Tier 2 capital for the purposes of the Reserve Bank of New Zealand framework relating to the capital adequacy of banks.

Description: This Standard Practice Statement sets out Inland Revenues practice for considering requests for the Commissioners approval to change a balance date for income tax purposes.

Description: The Court of Appeal was satisfied that the Commissioner of Inland Revenue was correct in refusing to allow Patty Tzu Chou Lin a further credit for New Zealand tax payable on her attributed Controlled Foreign Companies ('CFC') income for the tax totalling $588,135.91 that the CFCs had been spared from paying in China under Chinese domestic law.

Description: New Zealand's list of participating jurisdictions made by determination for the purposes of the CRS applied standard (CRS) and requirements under Part 11B of the Tax Administration Act 1994 on the 21st of June 2017 will be amended with effect from the 1st of April 2018.

Description: The disputant is a solicitor in sole practice who claimed two deductions for bad debts in respect of loans he had extended to clients of his legal practice. The Taxation Review Authority ('the Authority') found that the deductions were not allowed because the disputant had not shown that he had written the debts off as bad in the income year in which he had claimed them, nor were the debtors released from their obligations to pay by operation of law in that income year. Furthermore, the Authority found that the disputant had not satisfied the requirement of carrying on a business which included dealing in or holding financial arrangements. A shortfall penalty was imposed for not taking reasonable care under s 141A of the Tax Administration Act 1994.

Description: This article provides detail of the 2018 square metre rate for the dual use of premises. This rate is set in accordance with section DB 18AA of the Income Tax Act 2007.

Description: The Revenue Alert sets out some of the factors that would cause tax avoidance concerns. In general, transactions where a person sells shares in one company to another company in which they have a significant interest in, then depending on the way the transaction has been structured, section BG 1 (or GB 1) may apply.

Description: This ruling covers the reclassification of two classes of shares (Co-operative Control Shares and Investment Shares) into a single, continuing class of shares (Ordinary Shares) listed on the New Zealand Alternative Market Exchange (NZAX).

Description: This ruling applies to a BNZ product called TotalMoney, a package of accounts and loans offered to customers. TotalMoney allows customers to group or aggregate accounts for the purposes of either 'pooling' or 'offsetting' the account balances.

Description: This item considers when an arrangement (the revised arrangement) will be 'materially different' from the arrangement identified in a private or product ruling for the purpose of ss 91EB(2)(a) and 91FB(2)(a) of the Tax Administration Act 1994. It concludes that the revised arrangement is 'materially different' if, in relation to a tax type, the difference between the revised arrangement and the arrangement identified in the ruling is capable of affecting the tax outcome referred to in the ruling. Whether the revised arrangement is materially different from the arrangement identified in the ruling will depend on the facts and circumstances of the case.

Description: Share purchase scheme account maintained by CRS Nominees Limited is an excluded account for the purposes of the CRS applied standard and requirements under Part 11B of the Tax Administration Act 1994.

Description: This determination relates to a funding transaction involving the issue of Notes by Bank to Group Member pursuant to a Deed Poll. The Notes will contain a conversion mechanism to allow them to be recognised as Tier 2 capital for the purposes of the Reserve Bank of New Zealand framework relating to the capital adequacy of banks.

Description: This Standard Practice Statement sets out Inland Revenues practice for considering requests for the Commissioners approval to change a balance date for income tax purposes.

Description: The Court of Appeal was satisfied that the Commissioner of Inland Revenue was correct in refusing to allow Patty Tzu Chou Lin a further credit for New Zealand tax payable on her attributed Controlled Foreign Companies ('CFC') income for the tax totalling $588,135.91 that the CFCs had been spared from paying in China under Chinese domestic law.

Description: The disputant is a solicitor in sole practice who claimed two deductions for bad debts in respect of loans he had extended to clients of his legal practice. The Taxation Review Authority ('the Authority') found that the deductions were not allowed because the disputant had not shown that he had written the debts off as bad in the income year in which he had claimed them, nor were the debtors released from their obligations to pay by operation of law in that income year. Furthermore, the Authority found that the disputant had not satisfied the requirement of carrying on a business which included dealing in or holding financial arrangements. A shortfall penalty was imposed for not taking reasonable care under s 141A of the Tax Administration Act 1994.

Description: This article provides detail of the 2018 square metre rate for the dual use of premises. This rate is set in accordance with section DB 18AA of the Income Tax Act 2007.