Table of contents
Preface
Table of contents
Chapter 1 – An overview
1.1 Introduction
1.2 Brief overview of this discussion document
1.3 Submissions
Chapter 2 – Policy making considerations
2.1 Introduction
2.2 Outline of the chapter
2.3 The broad aim of international tax policy
2.4 Influences on investment
2.5 The source of capital - domestic or foreign
2.6 The impact of taxes
2.7 The problem of double taxation
2.8 The role of tax treaties and tax administration considerations
2.9 The relationship between domestic and international tax
2.10 Foreign tax credits received by non-residents
2.11 Other important considerations
2.12 Conclusion
Chapter 3 – The current tax regime
3.1 Current tax treatment of foreign-sourced income of New Zealand residents
3.2 Current tax treatment of non-residents - general comments
3.3 Taxation of income to non-residents from "portfolio" investment
3.4 Conclusion
Chapter 4 – Problems with the existing rules measuring cross-border income
4.1 Introduction
4.2 Source rules - technical problems
4.3 Absence of adequate transfer-pricing rules and approved methodologies
4.4 Variability of tax rates
4.5 Conclusion
Chapter 5 – Proposed programme for reform
5.1 Introduction
5.2 The reform package
5.3 Extension of the FITC regime
5.4 New transfer-pricing rules
5.5 Improved source rules
5.6 Consideration of thin-capitalisation rules
5.7 Conclusion
Chapter 6 – Extension of tax credits to foreign direct investment
6.1 Introduction
6.2 Objective of the proposed extension of the FITC regime
6.3 Compliance costs of the extension
6.4 Fiscal costs of the extension
6.5 Implications for the branch profits tax
6.6 Conclusion
Chapter 7 – Proposed new transfer-pricing and source rules
7.1 Introduction
7.2 The proposed new transfer-pricing rules
7.3 Integration with the rest of the Act
7.4 Improved source rules
7.5 Other possible changes to the source rules to be considered
7.6 Effective date
Chapter 8 – Thin-capitalisation considered
8.1 Introduction
8.2 Parameters of an effective thin-capitalisation regime
8.3 Description of a possible effective thin-capitalisation regime
8.4 Debt:Equity ratio
8.5 Thin-capitalisation rules - issues for submissions
8.6 Conclusion