Volume 37 No 8 Tax information bulletin September 2025
Determinations
- 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
Interpretation statement
- IS 25/18: Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust
Questions we've been asked
- QB 25/18: Does GST apply to a deposit the seller retains in a cancelled land sale agreement?
- QB 25/19: GST listed services rules: When is a supply of listed services made through an electronic marketplace?
- 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?
Technical decision summaries
- TDS 25/17: Application of schedular payment rules
- TDS 25/18: Sale of intellectual property, shares and ongoing provision of services
- TDS 25/19: Company restructure for commercial and estate planning
- TDS 25/20: Transfer of property between charitable trusts
TDS 25/21 Omitted income and shortfall penalty
GA 25/01 Tax on any fees paid to a member of a board, committee, panel, review group or task force
This item is an update of GA 21/01 which was prepared specifically in relation to the fees paid to a member of a board, committee, panel, review group or task force under the Cabinet Fees Framework published by the Cabinet Office.
How taxation applies to any fees paid to members depends on the personal circumstances of the individual member and the terms of their contract/appointment.
This fact sheet accompanies IS 25/18: Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust. It will be of interest to New Zealand tax residents who receive money or property from overseas that may possibly be taxable in New Zealand and to their tax advisors.
TDS 25/20 Transfer of property between charitable trusts
This item summarises a private ruling about whether the market value of properties and chattels transferred between charitable trusts is taxable when the transferors deregister as charitable entities.
This interpretation statement considers the income tax treatment of amounts of money or property that New Zealand tax residents receive from a person overseas, including through inheritance. It addresses how to determine whether the person who transfers the money or property is a trustee of a trust and when the resident taxpayer has derived beneficiary income or a taxable distribution from a foreign trust.
TDS 25/19 Company restructure for commercial and estate planning
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
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: High Court dismisses judicial review of decisions to decline proposals for relief under s 177 of the TAA
- 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
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.
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.
Reference | Title | Closes |
---|---|---|
PUB00478 | Income tax - business activity | 05 September 2025 |
PUB00476 | GST – taxable activity | 08 September 2025 |
PUB00520 | GST – Meaning of payment | 10 September 2025 |
PUB00514 | GST – Secondhand goods input tax deduction | 10 September 2025 |
PUB00492 | Do the purchase price allocation rules alter the tax book values of Farmland Improvements and listed horticultural plants under subpart DO? | 15 September 2025 |
PUB00491 | Can a farmer who leases land deduct the tax book value of horticultural plants on the land when the lease ends? | 15 September 2025 |
PUB00521 | Income tax – Public private partnership projects and business continuity test for losses | 19 September 2025 |
PUB00500 | Shortfall penalties – s 141A, 141B and 141C of the Tax Administration Act 1994 | 31 October 2025 |
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Consultations closing soon
PUB00478: Income tax - business activity
Consultation closes 5 September 2025