International Tax Reform Part 1, Report of the Consultative Committee

This document is the first part of the report on the introduction of international tax measures by the Consultative Committee on Full Imputation and International Tax Reform. The report sets out the major building blocks of the regime recommended by the committee following its review of the regime contained in the Consultative Document and the many public submissions received. The major recommendation is that the branch-equivalent method of taxation should apply in respect of New Zealand residents' interests in foreign companies only where there is control. Where there is not control, the comparative value method of taxation should apply, but only to a limited range of investments (foreign investment funds). To streamline the operation of the branch equivalent method and reduce compliance costs, an exemption is recommended for taxpayers having interests in entities that are in designated countries and that do not benefit from significant tax preferences. Transitional arrangements are also recommended