The aim of this article is to point to a flaw in one of the measures recently enacted by the New Zealand Government to prevent tax avoidance by large multinational enterprises (MNEs). That measure is section GB 54 of the Income Tax Act 2007, which was added to the Act in July 2018 and which is...

The OECD has for several years been laboriously attempting to reform the international tax system so as to rectify the gross under-taxation of heavily digitalized firms such as Google, Facebook and eBay. Progress has been slow, though, so a number of countries, including New Zealand, have...

This paper examines the evolution of the New Zealand tax system from 1845 to 1876. The key to this period is the New Zealand Constitution Act 1852 (UK), which was devised by the Governor, Sir George Grey, and which divided the Colony into six provinces. There were hardly any roads, so allowing...

New Zealand is in general a high tax country. It is host to a thriving offshore trust industry established after an amendment to the income tax legislation in 1987. The successor to this amendment is section HC 26(1), which means that where non-residents settle income-producing property on New...

There is an active but unpublicised industry of New Zealand trustees who look after foreigners’ money. Also, taxpayers from other countries sometimes use New Zealand as a haven. Some trustees for foreign funds have a reasonably substantial presence in New Zealand; others may be single-purpose...

For any country, working out the most appropriate method of taxing its residents' interests in foreign investment funds poses difficult challenges of regime design. Unlike some problems of tax design, the optimum structure of a foreign investment fund regime is likely to vary with the size of...

The article explores the legacy of British tax concepts on the development of New Zealand tax laws. After an historical sketch of the legislation leading through to the total rewrite of income tax law in plain English user-friendly style in the Income Tax Act 2007, the article charts the moves...

Over the last few years, the governments of both Australia and New Zealand have introduced a range of measures to encourage venture capital investments in small and medium-sized enterprises (SMEs). The schemes are heavily regulated and have been specifically designed to support the development...

This paper seeks to compare the wine tax regimes in South Africa, Australia and France. The aim of comparing these indirect taxes is to help inform the debate about the indirect taxation of wine. The paper examines these wine tax policies based on the generally accepted tax policy criteria of...