For 70% of this meandering, vacuous article I wondered just where Peter Dunne was going with his inflammatory subject line?
After all, for someone who was the Minister of Revenue for “nine” years, what self-confessions was he making about his failings as Parliamentary leader of the country’s tax system?read more
Management and directors need to be aware that tax rulings can be precarious, and can provide a false sense of security. Tax rulings are only as good as they actually apply, and demand active ongoing management. In some sense, the situation of insurance policies comes to mind here, where readers will be aware that the ‘devil is in the detail’ as to whether claims are covered, or not.
In this article, I canvass:-
What tax rulings can be sought from the IRD?
What are the main points of a tax ruling?
What are some of the pitfalls in seeking binding rulings?
Developments from IRD on issuing and challenging their tax rulings;
Many of these rules are permissive, yet in my experience many companies, and practitioners, fail to maximise the advantages that are available, or just get it wrong. Optimising available choices to reduce the corporate tax bill, and related cash outflows, is quite simply a ‘no-brainer’.
This article highlights some of the Valuable Lessons and Options that are available, and includes:
Loss offset methods – automatic transfer election, or subvention payment?
What is an eligible New Zealand loss offset group? Less than 100% wholly owned companies, and, resident and non-resident companies, and, part year entities;
Advantages with making subvention payment loss offsets;
How to properly effect a transfer of tax losses?
Some traps, tips, and lessons.
For many years, New Zealand tax law and practice has been an uncertain minefield for group debt rationalisations that has demanded intricate and lengthy planning to fulfil this corporate endeavour without tripping up.
However, the passage of tax law in 2017 has finally brought some common sense and certainty to the outcomes from debt remission and, with this, paved the way for New Zealand corporates to rationalise and unwind their accumulated inter-company loans with impunity.read more
In this article, I address:-
The terms of reference, and what areas of NZ tax law will attract attention;
Has the Government got it right with the composition of this TWG?;
Drawing from prior tax working groups
What can we expect? Substantive overhaul, or fine tuning?
NZ’s tax engine is like a plug-in hybrid. We can expect some remedial changes and improvements, but the well spec’d car will remain, albeit in the shape of the next generative fully electric model.
In an over-hyped climate of generalisations about "profit stripping" foreign multinational companies, these two pieces of research demonstrate that (a) New Zealand's tax system is a robust one, and (b) the large majority of foreign owned NZ subsidiaries...read more
New Zealand companies pay out more profits as dividends than any other country in the world, with an average distribution of 77% of post tax earnings. Australian corporates are second only to New Zealand with a dividend pay-out ratio of 73%. The common...read more