Tax Policy

Following the enactment of the Taxation (Neutralising Base Erosion and Profit Shifting) Act earlier this year, Inland Revenue is now issuing draft guidance material to help taxpayers comply with the new legislation. Our intention is that the information that we provide is useful and (given the technical nature of the material) as clear and understandable as possible. This document covers the new rules aimed at:

- Interest limitation

- Hybrid mismatch arrangements

- Transfer pricing

- Permanent establishment avoidance, and

- Administrative measures

To help ensure that the coverage of these topics is useful to the public, we are providing this in draft format for public feedback. This will allow readers to see the form of the guidance, the direction it takes and the level of detail. Readers will be able to gauge for themselves what areas more explanation is required.

We will use feedback on this draft material to improve the content and presentation of the material. The finalised guidance will be published early in the new year.

Send your comments or questions to policy.webmaster@ird.govt.nz with “BEPS draft guidance” in the subject line.

Alternatively, send your comments to:

BEPS draft guidance
C/- Deputy Commissioner Policy and Strategy
Inland Revenue Department
P O Box 2198
Wellington 6140

The closing date for comments is 28 September 2018.

An amendment to New Zealand’s double tax agreement with Hong Kong has now entered into force. The amendment widens the exchange of information provisions for the purposes of eradicating tax evasion and avoidance. It brings the agreement with Hong Kong into line with the majority of New Zealand’s other double tax agreements by enabling the automatic exchange of information between the two tax jurisdictions. For more information see the Minister of Revenue’s media statement.