This document is the final report of the Consultative Committee on Full Imputation and International Tax Reform. This final report outlines the Committee's recommendations on the outstanding issues relating to both sets of reforms. It explains the policy behind draft legislation produced by the...

New Zealand employs a full imputation system for company taxation. That is, to avoid double taxation of corporate profits companies may impute, or pass on proportionately to their shareholders, the benefit of all tax paid at company level. The present document is the report of the Consultative...

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...

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...

Delegates from the Institute of Policy Studies at Victoria University of Wellington and the Australian Tax Research Foundation met with taxation experts from Canada and Sweden. The two countries have well developed advance rulings procedures. The questions that the meeting discussed are set out...

In 1985 New Zealand had a tax system that taxed corporate profits twice, first in the hands of the company and secondly in the hands of the shareholder, known as the “classical system”. The paper suggests how dividends from capital sources ought to be treated if this double taxation is to...

The Matrimonial Property Act 1976 deals with the division of property on the dissolution of marriage. Section 21(1) of the Act allows parties to contract out of the Act, which has led to a practice of using the section to put estate plans into place. The effect of these schemes allows parties to...

LexisNexis New Zealand has kindly consented to the classic text, John Prebble The Taxation of Property Transactions (1985) being posted on the SSRN website. Statutory references are to sections as numbered in the Income Tax Act 1976, but apart from re-numbering and reorganisation, the law in the...

In 1987, New Zealand taxpayers could avoid tax by establishing foreign corporations in which they held a controlling shareholding in low tax jurisdictions. This avoidance could occur in two ways. First, through using the foreign corporation to intercept passive income, such as interest or...

As commercial transactions and tax law have both become more complex, tax practitioners have called for the establishment of procedures whereby taxpayers can find out in advance the official opinion of the revenue authorities as to the tax implications of their proposed transactions. If formally...