Inland Revenue - Tax policy Tax Policy

News and information about the Government's tax policy work programme, including:
- proposed changes to the laws that Inland Revenue is responsible for
- updates on the progress of bills through Parliament
- policy announcements

Contents


Bill overview

General Bill issues

Interest limitation rules

Permanent establishment anti-avoidance rule

Transfer pricing and country-by-country reporting

Hybrid and branch mismatch rules

Other policy matters

Miscellaneous issues


Bill overview

General Bill issues

Interest limitation rules

Overview

General

Application to the same groups as thin capitalisation

Adjusted credit ratings

Disregarded features

Insuring or lending persons

Thin capitalisation – exclusion of non-debt liabilities

Infrastructure project finance

Other thin capitalisation

Permanent establishment anti-avoidance rule

Overview

General

Application of the rule

Role of the facilitator

Purpose of avoidance test

Administrative matters

Other matters

Permanent establishment source rule

Dta source rule

Transfer pricing and country-by-country reporting

Transfer pricing

Overview

Country-by-Country reports

Overview

Hybrid and branch mismatch rules

Overview

General issues

Hybrid Financial instrument rule

Disregarded hybrid payments rule and deemed branch payments

Reverse hybrid rule and branch payee mismatch rule

Deductible hybrid and branch payments rule

Dual resident payer rule

Imported mismatch rule

Surplus assessable income

Election Rules

Interaction with other tax regimes

Other definitions

NRWT on hybrid arrangements – treaty issue

Other policy matters

Inland Revenue’s administrative powers to investigate large multinationals

Overview

Life reinsurance

Miscellaneous issues