Capital gains taxes -- a comparative survey / Michael Littlewood -- The impact of economic theory on capital gains tax reform proposals / David White -- International aspects of capital gains taxation / Craig Elliffe -- Australia / Ann O'Connell -- Canada / David G. Duff -- China / Yan Xu --...

Assessing BEPSThe government has reviewed New Zealand's current policy settings and determined that most are robust and fit for purpose. Having identified hybrid mismatch arrangements, interest allocation and transfer pricing as issues that may need addressing, it is developing and refining its...

On January 28, 2003 changes were made to the Commentary on Article 1 which deals with the improper use of double tax conventions. Most countries, generally speaking, seem to accept that the general anti-avoidance rules will operate and can be reconciled with the provisions of their double tax...

This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

This article examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by non-residents or to some limited subset of those assets...

This article discusses the current state of tax treaty interpretation in New Zealand with particular reference to a recent decision which has attracted attention both here in New Zealand and overseas. The case concerned whether a New Zealand resident was entitled to a tax sparing credit under...