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...

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...

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...

There is no doubt that the tax laws of many countries are complex and difficult to comply with administratively. In particular, Australia, New Zealand and the United States have tax systems that are generally recognized as complex especially for small businesses. They also have the distinction...