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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 25/14 Business restructure

06 Jun 2025 Technical decision summary / 2025
The restructure of a business to change the ownership structure.

Volume 37 No 5 TIB - June 2025

03 Jun 2025 TIB / Volume 37 - 2025

New legislation

  • Public Act 2025 No 09: Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025
  • SL 2025/64: Income Tax (Fringe Benefit Tax, Interest on Loans) Amendment Regulations 2025
  • SL 2025/65: Taxation (Use of Money Interest Rates) Amendment Regulations 2025

Operational statements

  • OS 25/03: Authority to Act for Tax Agents, Representatives and Nominated Persons: Access to a Client’s Inland Revenue Information 

Interpretation statements

  • IS 25/14: Income tax – arrangements involving tax losses carried forward under the business continuity rules
  • IS 25/15: Look-through companies and disposal of residential land under the bright-line test

Questions we’ve been asked

  • QB 25/07: What is the income tax treatment of gift cards and products provided as trade rebates or promotions?
  • QB 25/08: When is land acquired for a purpose or with an intention of disposal so that the amount derived from the sale is income?
  • QB 25/09: When do I have a “regular pattern” of transactions that prevents me from using exclusions from the land sale rules for my residence or for my main home?
  • QB 25/10: On what date is a person treated as acquiring land for the purposes of the land sale rules?
  • QB 25/11: When is the bright-line start date for the 2-year bright-line test?
  • QB 25/12: How does the bright-line test apply to the sale of a subdivided section?
  • QB 25/13: When is the sale of a lifestyle block excluded from the bright-line test?
  • QB 25/14: When does the business premises exclusion to the bright-line test apply?
  • QB 25/15: How do the bright-line rollover relief provisions apply to transfers of residential land between associated persons?

Case summaries

  • CSUM 25/05: NZTCRA rejects argument that an interest amount paid under a relationship property agreement was deductible as an expense under the Income Tax Act 2007
  • CSUM 25/06: NZTCRA finds work to convert retail space to office space in commercial building was capital in nature
  • CSUM 25/07: NZTCRA finds remediation work on unit was capital in nature

Technical decision summary

  • TDS 25/08: Disposal of shares following amalgamation
  • TDS 25/09: Distribution and resettlement of trusts
  • TDS 25/10: Source of income and foreign tax credits
  • TDS 25/11: Deductions, zero-rating and shortfall penalties
  • TDS 25/12: Deductions and shortfall penalties

DET 09/02 (CPI 2025) 2025 CPI Adjustment for Determination DET 09/02: Standard-cost household service for childcare providers

30 May 2025 Determinations / Standard-cost household service / Childcare providers / 2025

This update to determination DET 09/02 shows the annual adjustment to the standard-cost household service for childcare providers.

DET 19/01 (CPI 2025) 2025 CPI adjustment to DET 19/01: Household boarding service providers

30 May 2025 Determinations / Standard-cost household service / Boarding service providers / 2025

This update to DET 19/01 shows the annual adjustment to the standard-cost household service for boarding service providers.

DET 19/02 (CPI 2025) 2025 CPI adjustment to DET 19/02: Short-stay accommodation

30 May 2025 Determinations / Standard-cost household service / Short-stay accommodation / 2025

This update to DET 19/02 shows the annual adjustment to the standard-cost household service for short-stay accommodation.

OS 19 04 (KM 2025) Kilometre rates for the business use of vehicles for the 2025 income year

30 May 2025 Operational statements / 2025

The rates set out below apply for the 2024-2025 income year for business motor vehicle expenditure claims. The Tier 1 and Tier 2 rates reflect an overall increase in vehicle running costs in the income year, largely due to fuel costs.  The Commissioner uses third-party data to set the appropriate kilometre rates for the income year.

OS 19 03 (CPI 2025) 2025 CPI adjustment to Operational Statement OS 19/03: Square metre rate for the dual use of premises

30 May 2025 Operational statements / 2025

This update to OS 19/03 shows the annual adjustment to the square metre rate for the dual use of premises.

NAMV 2025 National Average Market Values of Specified Livestock Determination 2025

26 May 2025 Determinations / Livestock / Average market value
This determination establishes the national average market value (NAMV) of specified livestock for 2025.

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

23 May 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) explains how the income tax rules apply when a close company provides short-stay accommodation (eg, through Airbnb, Bookabach, Booking.com or Holiday Houses). It explains when and how the mixed-use asset rules and the standard tax rules apply, and when shareholders or employees will receive income from their use of the property.

TDS 25/13 Income tax - land transferred within a consolidated tax group

19 May 2025 Technical decision summary / 2025
Intragroup land transactions, consolidation rules, distribution in kind

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National average market values of specified livestock

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Kilometre rates for the business use of vehicles

Square metre rate for the dual use of premises


Consultations closing soon

ED0259: Tax on any fees paid to a member of a board, committee, panel, review group or task force

Closes on 11 June 2025