The most common scenario where a company might issue shares and declare the issue to be a taxable bonus issue, is before a sale and purchase of shares of that company. Usually this will be undertaken at the behest of the continuing shareholders. Pre-sale, advisers will have identified that the sale and purchase of shares…

A corporate structure is recommended for trading internationally, for creditor and asset protection reasons. Often a special purpose company is used to isolate the foreign operation from the NZ business. Practitioners who advise NZ businesses on structuring overseas operations will be well aware of the issue of double taxation. Briefly, double taxation arises in a…

The Inland Revenue (IR) has confirmed NZ trusts can have a dual classification for tax purposes, as both a complying trust and a foreign trust. This comes as IR have finalised their updated Interpretation Statement on the Taxation of Trusts. It’s not an unusual situation to have a dual trust. For example, NZ’ers who are…

Inland Revenue recently issued a draft interpretation statement, PUB0061, on NZ tax law as it applies to trusts. The draft statement seeks to update the 1989 statement, and we attach a copy of our submission on certain of the tax issues that we thought deserved comment. Once the statement is finalised, it will become Inland…

We have attached a summary of tax issues to consider for New Zealand inbound migrants. New Zealand inbound migrants tax treatment

  Be aware of the changes set to apply from 1 April 2017 for GST zero rating of services to non-residents for land transactions   Background The forthcoming GST changes will affect services provided to non–residents by New Zealand resident lawyers, estate agents, architects, engineers and any other service provider in relation to land. In general…

The NZ Government’s moves to legislate for more transparency in the foreign trusts regime may lead to some non-resident’s packing up and shifting their foreign trust away from NZ to a more benign regime. Increased disclosure, yet the non-taxing of foreign sourced income derived by NZ foreign trusts will remain untouched by the foreign trust…

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