Skip to main content
Inland Revenue

Tax Policy

Index of BEPS documents

# Date Type Title and description Download
01 9 March 2017 Policy report

Consultation on addressing hybrid mismatch arrangements

Report on submissions received for the Government's discussion document Addressing hybrid mismatch arrangements (September 2016) – for the submissions see document #21.

Report number: IR2017/133, T2017/0406

PDF
(1.7 MB; 23 pages)

DOCX
(206 KB; 23 pages)

02 6 April 2017 Policy report

Cabinet paper Foreign hybrid entity double deductions and BEPS reforms

Covering report for Cabinet paper (document #03).

Report number: IR2017/237, T2017/949

PDF
(302 KB; 3 pages)

DOCX
(164 KB; 3 pages)

03 6 April 2017 Cabinet paper

Foreign hybrid entity double deductions and BEPS reforms

Cabinet paper with recommendations for foreign hybrid entity double deductions and BEPS reforms.

PDF
(85 KB; 8 pages)

DOCX
(75KB; 8 pages)

04 18 April 2017 Policy report

New Zealand’s adoption of the OECD’s Multilateral Instrument

Report covering:

  • submissions received for the officials’ issues paper New Zealand’s implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (March 2017) – for the submissions see document #23; and
  • the Multilateral Instrument Cabinet paper (document #05).

Report number: IR2017/260, T2017/1004

PDF
(2.5 MB; 25 pages)

DOCX
(203 KB; 25 pages)

05 18 April 2017 Cabinet paper

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting: Approval for Signature and Ratification

Cabinet paper with recommendations on the text and agreement to sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting.

Reference: CAB-17-SUB-0241

Source version for each section:

  1. Cabinet submission summary - PDF (136 KB; 2 pages; only available as a PDF)
  2. Cabinet paper - DOCX (52 KB, 15 pages; some formatting differences)
  3. Annex A – Text of the Multilateral Instrument (included in Cabinet paper)
  4. Annex B – New Zealand's notifications and reservations - DOCX (104 KB; 29 pages)
  5. Annex C (included in Cabinet paper)
  6. Annex D – National Interest Analysis (DOCX 74KB; 24 pages)

PDF
(846 KB; 76 pages)

06 18 May 2017 Policy report

Update on Multilateral Instrument

Report with recommendations to add additional countries to New Zealand’s list of double tax agreements covered by the Multilateral Instrument.

Report number: IR2017/320, T2017/1363

PDF
(321 KB; 3 pages)

DOCX
(160 KB; 3 pages)

07 15 June 2017 Policy report

BEPS – summary of submissions on March 2017 discussion documents

Report on the submissions received for the Government's discussion documents BEPS – Transfer pricing and permanent establishment avoidance (March 2017) and BEPS – Strengthening our interest limitation rules (March 2017).

Report number: IR2017/361, T2017/1630

PDF
(1.1 MB; 16 pages)

DOCX
(192 KB; 16 pages)

08 22 June 2017 Policy report

Base erosion and profit shifting – overview of current reports

Report with an overview of the 22 June 2017 reports about base erosion and profit shifting (documents #09, #10, and #11).

Report number: IR2017/329, T2017/1578

PDF
(535 KB; 6 pages)

DOCX
(174 KB; 6 pages)

09 22 June 2017 Policy report

BEPS – interest limitation submissions and policy decisions

Report on submissions and policy changes resulting from the Government's discussion document BEPS – Strengthening our interest limitation rules (March 2017) – for the submissions see document #22.

Report number: IR2017/325, T2017/1576

PDF
(2.4 MB; 34 pages)

DOCX
(224 KB; 34 pages)

10 22 June 2017 Policy report

BEPS – transfer pricing and permanent establishment avoidance submissions and policy decisions

Report on submissions and policy changes resulting from the Government's discussion document BEPS – Transfer pricing and permanent establishment avoidance (March 2017) – for the submissions see document #24.

Report number: IR2017/330, T2017/1577

PDF
(2.1 MB; 29 pages)

DOCX
(222 KB; 29 pages)

11 22 June 2017 Policy report

BEPS Recommendations on addressing hybrid mismatch arrangements

Report with recommendations on policy changes for addressing hybrid mismatch arrangements.

Report number: IR2017/353, T2017/1604

PDF
(3.4 MB; 53 pages)

DOCX
(467 KB; 53 pages)

12 6 July 2017 Policy report

Cabinet paper – tax measures to prevent base erosion and profit shifting

Covering report for Cabinet paper (document #13).

Report number: IR2017/410, T2017/1847

PDF
(472 KB; 5 pages)

DOCX
(164 KB; 5 pages)

13 13 July 2017 Cabinet paper

Tax measures to prevent base erosion and profit shifting

Cabinet paper with an overview of the three Cabinet papers recommending measures to address base erosion and profit shifting in New Zealand (documents #15, #17, and #19).

PDF
(156 KB; 17 pages)

DOCX
(68 KB; 17 pages)

14 13 July 2017 Policy report

BEPS Cabinet papers

Covering report for the three BEPS Cabinet papers: strengthening our interest limitation rules, transfer pricing and permanent establishment avoidance, and addressing hybrid mismatch arrangements.

Note: The PDF version of this document includes the Cabinet papers and signed regulatory impact assessments – these are also listed individually (documents #15–#20).

Report number: IR2017/429, T2017/1901

PDF
(4.5 MB; 100 pages)

DOCX
(165 KB; 3 pages; covering report only)

15 13 July 2017 Cabinet paper

BEPS – strengthening our interest limitation rules

Cabinet paper on proposals for strengthening our interest limitation rules.

PDF
(83 KB; 9 pages)

DOCX
(43 KB; 9 pages)

16 13 July 2017 Regulatory impact assessment

BEPS – strengthening our interest limitation rules

Regulatory impact assessment on proposals for strengthening our interest limitation rules.

PDF
(177 KB; 22 pages)

PDF - Signed
(1.5 MB; 22 pages)

DOCX
(75 KB; 22 pages)

17 13 July 2017 Cabinet paper

BEPS – transfer pricing and permanent establishment avoidance

Cabinet paper on proposals for transfer pricing and permanent establishment avoidance rules.

PDF
(81 KB; 8 pages)

DOCX
(47 KB; 8 pages)

18 13 July 2017 Regulatory impact assessment

BEPS – transfer pricing and permanent establishment avoidance rules

Regulatory impact assessment on proposals for transfer pricing and permanent establishment avoidance rules.

PDF
(161 KB; 21 pages)

PDF - Signed
(1.3 MB; 21 pages)

DOC
(180 KB; 21 pages)

19 13 July 2017 Cabinet paper

BEPS – addressing hybrid mismatch arrangements

Cabinet paper on proposals for addressing hybrid mismatch arrangements.

PDF
(181 KB; 21 pages)

DOCX
(280 KB; 21 pages)

20 12 July 2017 Regulatory impact assessment

BEPS Hybrid mismatch arrangements

Regulatory impact assessment on proposals for hybrid mismatch arrangements.

PDF
(150 KB; 16 pages)

PDF - Signed
(1.3 MB; 16 pages)

DOC
(172 KB; 16 pages)

21 September to November 2016

Submissions

Addressing hybrid mismatch arrangements

20 submissions received for the Government’s discussion document Addressing hybrid mismatch arrangements (September 2016).

Individual submissions

PDF
(17.5 MB; 299 pages)

22 March to May 2017

Submissions

BEPS – Strengthening our interest limitation rules

27 submissions received for the Government’s discussion document BEPS – Strengthening our interest limitation rules (March 2017).

Individual submissions

PDF
(20.2 MB; 268 pages)

23 April 2017

Submissions

New Zealand’s implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

5 submissions received for the officials’ issues paper New Zealand’s implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (March 2017).

Individual submissions

PDF
(2.8 MB; 50 pages)

24 April to May 2017

Submissions

BEPS – Transfer pricing and permanent establishment avoidance

16 submissions received for the Government’s discussion document BEPS – Transfer pricing and permanent establishment avoidance (March 2017).

Individual submissions

PDF
(14.8 MB; 186 pages)