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This site contains the Commissioner’s interpretation of tax law, our Work Programme for the year, and where you can provide feedback on any new work underway or apply for a binding tax interpretation. Publications on this Tax Technical website are correct at the date of issue. Read more
This site contains the Commissioner’s interpretation of tax law. Read more

TDS 25/19 Company restructure for commercial and estate planning

04 Aug 2025 Technical decision summary / 2025
This item summarises a private ruling that considered whether a company restructure for commercial and estate planning is tax avoidance.

Volume 37 No 7 Tax information bulletin - August 2025

01 Aug 2025 TIB / Volume 37 - 2025

New legislation

  • Taxation (Budget Measures) Act 2025 commentary

Operational statements

  • OS 25/04: The Commissioner of Inland Revenue’s search powers
  • OS 25/05: Section 17B Notices

Question we've been asked

  • QB 25/17: Income tax: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset?

Case summaries

  • CSUM 25/10: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime
  • CSUM 25/11: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime

Technical decision summaries

  • TDS 25/15: GST – input tax deductions, grants, omitted sale
  • TDS 25/16: Charitable trust – transfer of assets

QB 25/19 GST listed services rules: When is a supply of listed services made through an electronic marketplace?

28 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) discusses one of the key requirements for when the GST listed services rules apply. That is, the supply must be made by an underlying supplier to a recipient through an electronic marketplace operator. It explains that this requirement is satisfied when the marketplace is involved in, and facilitates, supplies between underlying suppliers and recipients.

QB 25/20 GST listed services rules: How do the rules apply when there is a supply of listed services and other goods or services?

28 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) discusses some issues with identifying the relevant supplies for the GST listed services rules. It explains what listed services are and how to apply the GST listed services rules if a supply includes listed services with other goods or services.

TDS 25/18 Sale of intellectual property, shares and ongoing provision of services

25 Jul 2025 Technical decision summary / 2025
This item summarises a private ruling concerning a cross-border arrangement involving the sale of intellectual property, other assets, shares, and the provision of services between a New Zealand company and its offshore parent.

FDR 2025/05 Determination the fair dividend rate method may not be used to calculate FIF income by investors in the iShares Global Aggregate Bond ESG SRI UCITS ETF – EUR hedged (Accumulating) share class

17 Jul 2025 Determinations / International tax / Foreign investment funds / 2025
Any investment by a New Zealand resident investor in the EUR hedged (Accumulating) share class of the iShares Global Aggregate Bond ESG SRI UCITS ETF (ISIN IE000APK27S2), a sub-fund of iShares III Public Limited Company (iShares III), to which none of the exemptions in sections EX 29 to 43 of the Income Tax Act 2007 apply, is a type of attributing interest for which the investor may not use the fair dividend rate ("FDR") method to calculate foreign investment fund income for the interest when the investment is hedged to NZD by the New Zealand resident investor.

QB 25/18 Does GST apply to a deposit the seller retains in a cancelled land sale agreement?

15 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked explains the GST consequences when a land sale agreement is cancelled and the seller retains the deposit.

QB 25/17 Income tax: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset?

11 Jul 2025 Questions we've been asked / 2025

This question we’ve been asked is about whether a taxpayer can deduct for income tax purposes the amount of expenditure they have incurred to repair a capital asset that they have recently acquired.  The repairs in question are those that are essential so that the taxpayer can use it in their business or income-earning activity.

Tax Information Bulletin - Vol 37 No 7, August 2025  

TDS 25/17 Application of schedular payment rules

11 Jul 2025 Technical decision summary / 2025
This item summarises a private ruling about directorship services payments to non-residents and whether they are schedular payments.

Volume 37 No 6 Tax information bulletin - July 2025

01 Jul 2025 TIB / Volume 37 - 2025

Determinations

  • NAMV 2025: National Average Market Values of Specified Livestock Determination 2025
  • OS 19 04 (KM 2025): Kilometre rates for the business use of vehicles for the 2025 income year
  • 2025 Consumers Price Index adjustment to standard-cost amounts for household services (childcare, boarding services, or short-stay accommodation)
  • 2025 CPI adjustment to Operational Statement OS 19/03: Square metre rate for the dual use of premises
  • Det 25/02: Determination of expenditure incurred relating to payments made by New Zealand Clinical Research to volunteers
  • Det 25/03: Determination of amount of a particular payment (being per diem allowances paid in the screen production industry) that shall be regarded as expenditure incurred relating to those payments

Ruling

  • BR Prd 25/03: Extraordinary Pay Limited

Interpretation statements

  • IS 25/16: Tax residence
  • IS 25/17: Tax residence – government service rule

Question we’ve been asked

  • QB 25/16: Income tax – How do the income tax rules apply when a close company provides short-stay
    accommodation?

Case summaries

  • CSUM 25/08: Absence of evidence makes it impossible to prove nexus with the expenditure and the claimed deductions
  • CSUM 25/09: Lack of complete financial records secures TCRA win for the Commissioner in major income suppression case

Technical decision summaries

  • TDS 25/13: Income tax – land transferred within a consolidated tax group
  • TDS 25/14: Business restructure