Tax practitioners continue to face an environment of almost constant change, driven not only by legislative amendment but also by changing approaches to tax administration and enforcement and judicial attitudes to issues that reach the courts. 

A key issue for taxpayers within this environment is how best to achieve greater certainty in taking tax positions.  Methods of obtaining varying degrees of comfort from Inland Revenue are addressed in the joint Inland Revenue / tax advisor paper.

It is a significant year for no other reason than we have (in draft form for the time being) Inland Revenue’s Interpretation Statement on the application of the general anti-avoidance rule.  We will also receive a new edition of the tax advisor’s ‘bible’, in regards to the application of the financial arrangements rules: “Financial Arrangements – A Practical Guide”.  You will hear from its principal authors on topical issues, such as the interplay between the rules and the IFRS treatment of financial arrangements.

New Zealand’s relationship with the rest of the world (and its suitability as a destination for capital or a financial hub) is addressed in two international tax focused sections relating to DTAs and New Zealand’s sourced-based taxing rights to certain items of income.

Further domestic issues are also be addressed – trust taxation has given rise to a number of topical issues, including the ability to allocate deemed taxable income to beneficiaries and the responsibility of trustees for tax payable by trusts.

Authors: Vivian Cheng, Tim Clarke, Shaun Connolly, Bart de Gouw, Craig Elliffe, Teresa Farac, Patrick Goggin, Mike Hendriksen, Bevan Miles, Robin Oliver, John Payne, John Peterson, Casey Plunket, Martin Smith, Fred Ward, Sanjiv Weerasinghe, Tony Wilkinson