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...

From a tax policy point of view, one of the demerits of a foreign investment fund regime is that it causes the law to treat forms of investment that are similar in economic purpose and effect as if they were different. In particular, it I likely to distinguish between direct investments by...

The Taxation (Beneficiary Income of Minors, Service-Related Payments and Remedial Matters) Act 2001 taxes the income of most beneficiaries of trusts who are minors at 33 per cent. This measure responded to parents strategically diverting income to their children via trusts, with a view to that...

Sections HH 1 and HH 8 of the New Zealand Income Tax Act 1976 contain a special regime for the taxation of trusts. Income that is distributed by the trustee is taxed in the hands of the beneficiary, and income that is accumulated is taxed to the trustee. The mere fact of the trustee being...

Legislation regulating tax preparers has seen little attention in New Zealand, but this is not the case in Australia and the USA. In Australia is obligatory for those who professionally prepare tax returns to be registered as tax agents. In both countries – the USA and Australia – tax...

Several major changes in tax law were annouced in the 1991 Budget. These included changing the way dividends between companies were addressed and relaxing non-resident withholding tax on interest. The Government stated it would consider instituting an ongoing program of review of existing...

In the late 1980s New Zealand signaled its intention to pass legislation to prevent resident shareholders from using controlled foreign companies to avoid tax. Controlled foreign companies all operate in a similar fashion. The regimes apply to non-resident companies that are owned or controlled...

Tax measures in the 1989 Budget included a broadening of the base and reduction of the rates of land tax. As from May 1990 employers are to be required to account for compulsary deduction of “pay as you earn” income tax withheld from salaries and wages twice a month rather than once a month....

In the late 1980s New Zealand undertook a process of adopting a new income tax regime for companies, and in particular for controlled foreign companies. The new rules reflected a change from a classical to an imputation system. The rules were designed to frustrate avoidance deferral that was...

In 1984 New Zealand began a major programme of tax reform. The changes were part of wider economic reforms enacted by the Fourth Labour Government. There were large cuts to the level of income tax and an introduction of a Goods and Services Tax, that is, a VAT. The changes were favourable to...