New Zealand currently charges some classes of capital gains to income tax, but there is no tax on capital gains as such. The Tax Working Group recently established by the government has however recommended that there should be such a tax. That is, it has recommended that New Zealand should, like...

Tax avoidance by major US multinationals has been extremely topical over the last decade since the GFC. One of the MNEs at the forefront of this controversy is Google. It has been able to snare a dominant share of the international online advertising market without paying any significant amounts...

This article examines the international taxation of dividend, interest and royalty income derived through a trust. It concludes that New Zealand's general principles of international trust taxation and its international withholding rules can be reconciled by applying and re-applying the trust...

The oldest GAAR in the world is a somewhat crude instrument that has been honed to a very sharp edge by the New Zealand Supreme Court. The GAAR in New Zealand is classic evidence that, at least in New Zealand, such broadly worded anti-avoidance provisions are ultimately judge-made law. This is...

Since WW II there has been a rapid expansion in the number of bilateral double tax agreements (DTAs) concluded between countries. A feature of modern DTA negotiations has been the adoption of internationally accepted models or templates from which most DTAs are negotiated from. Although such...

The cash economy and associated tax evasion is an on-going issue for most tax administrators. Tax evasion reduces national tax revenue, shifts the tax burden on to other taxpayers such as salary/wage earners and undermines confidence in the tax system affecting voluntary compliance as well as...

New Zealand is unique in the OECD. It had an R&D tax credit but it was only in force for one tax year. There are currently no plans in place to reintroduce such a credit. There are, though, a number of provisions in the tax code that are R&D incentives in the strict sense of the term. While...

Despite the economic importance of small and medium enterprises (SMEs), little is known about their tax compliance perceptions, which may influence their compliance behavior. This is particularly so in relation to comparing the tax perceptions of New Zealand SMEs and their tax practitioners....

This paper analyses the methods adopted by Australia and New Zealand to tax companies and their shareholders in four key periods from 1945 to 2005. For each period the major concern of the paper is with an analysis of the factors contributing to effective tax rates for different types of...