Tax treaties that have been concluded by common law countries follow the basic structure, concepts, and language of model tax conventions that were promulgated by the OECD in 1963 and 1977. Thus, clauses from most treaties concluded by most common law countries are equally suitable as...

The deregulation that has been so much a feature of the New Zealand economy since the mid 1980s has been particularly evident in the banking industry. This development has seen the emergence of many new practices, practices that have often emerged so fast that there is still an imperfect...

A non-recourse loan is one made on terms where the borrower has no personal obligation to pay except from an identified fund of assets. It is usual for all or most of the assets in the fund to be subject to a charge in favour of the lender. This article considers the nature of the relationship...

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...

Among the possible responses to the problem of avoidance a country may enact a general anti-avoidance rule, couched in terms wide enough to frustrate tax planning strategies that have yet to be invented. One difficulty of general anti-avoidance rules is that they cannot be interpreted as undoing...

In his Technical Information Bulletin of February 1990 the Commissioner of Inland Revenue issued a policy statement on Section 99 of the New Zealand Income Tax Act 1976. Section 99 is a general anti-avoidance provision that voids for income tax purposes arrangements that have the purpose or...

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...

The New Zealand Income Tax Amendment Act 1989 completed the reform of the New Zealand laws on the taxation of superannuation schemes. The object was to bring the taxation of superannuation schemes into line with the taxation of other forms of saving. The Act introduces the specified...

The report of the Consultative Committee on the taxation of the life assurance industry was published on 4 September 1989. The report promotes fiscal neutrality by suggesting that the taxation of investment via life assurance should conform as closely as possible to the taxation of other forms...