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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

IS 25/16 Tax residence

16 May 2025 Interpretation statements / 2025
This interpretation statement explains the tax residence rules in the Income Tax Act 2007. It covers the tax residence of natural persons (individuals) and companies, and the residence implications in relation to trusts.

IS 25/16 FS 3 Tax residence and trusts fact sheet

16 May 2025 Fact sheets / 2025
This fact sheet accompanies IS 25/16: Tax residence and summarises the tax residence rules in the Income Tax Act 2007 relating to trusts. The interpretation statement explains the rules for individuals, companies and trusts in more detail. There are also fact sheets covering tax residence of individuals and companies.

IS 25/16 FS 2 Tax residence – companies fact sheet

16 May 2025 Fact sheets / 2025
This fact sheet accompanies IS 25/16: Tax residence and summarises the tax residence rules in the Income Tax Act 2007 relating to companies. The interpretation statement explains the rules for companies, individuals and trusts in more detail. There are also fact sheets covering tax residence of individuals and trusts.

IS 25/16 FS 1 Tax residence – individuals fact sheet

16 May 2025 Fact sheets / 2025
This fact sheet accompanies IS 25/16: Tax residence and summarises the tax residence rules in the Income Tax Act 2007 relating to individuals. The interpretation statement explains the rules for individuals, companies and trusts in more detail. There are also fact sheets covering the tax residence of companies and trusts.

IS 25/17 Tax residence – government service rule

16 May 2025 Interpretation statements / 2025
This interpretation statement explains the government service rule in the Income Tax Act 2007 and discusses the articles of double tax agreements that may need to be considered if the government service rule applies.

Depreciation

14 May 2025 Overviews

Most business assets lose value over time.  This loss is called depreciation.  Businesses can claim depreciation loss on certain assets as a deduction each tax year.

IS 25/15 Look-through companies and disposal of residential land under the bright-line test

12 May 2025 Interpretation statements / 2025
This interpretation statement explains how the bright-line rules (including the main home exclusion and rollover relief) apply in various situations involving residential land and transfers involving a look-through company. This interpretation statement applies only to transfers on or after 1 July 2024.

IS 25/15 FS Look-through companies and disposal of residential land under the bright-line test - fact sheet

12 May 2025 Fact sheets / 2025
This fact sheet accompanies an interpretation statement IS 25/15 Look-through companies and disposal of residential land under the bright-line test that explains how the bright-line test applies in various situations involving residential land and transfers involving a look-through company.

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?

09 May 2025 Questions we've been asked / 2025
This question we’ve been asked provides guidance about when someone will have a “regular pattern” of transactions that prevents them from using the residential exclusion from s CB 6, and when someone will have a “regular pattern” of transactions that prevents them from using the main home exclusion from the 2-year bright-line test.  It replaces (for disposals on or after 1 July 2024) QB 16/07: Income tax – land sale rules – main home and residential exclusions – regular pattern of acquiring and disposing, or building and disposing.

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?

09 May 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) provides guidance about the circumstances in which an amount derived from the disposal of land acquired with a purpose or intention of disposal is income under s CB 6.  The QWBA explains how s CB 6 applies, and its relationship with the 2-year bright-line test.  The QWBA also discusses some common misconceptions about s CB 6 and includes examples illustrating when it will apply.  It replaces QB 16/06: Income tax – land acquired for a purpose or with an intention of disposal.
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Reference Title Closes
PUB00484 The Commissioner’s duty of care and management – section 6A of the Tax Administration Act 1994 26 May 2025
ED0259 Tax on any fees paid to a member of a board, committee, panel, review group or task force 28 May 2025
PUB00469 Income Tax – Whether an off-market share cancellation is made in lieu of the payment of a dividend 03 June 2025
2025 26 work programme Public advice and guidance work programme 2025-26 06 June 2025
PUB00494 Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust 19 June 2025
ED0265 Mutual transactions of associations (including clubs and societies) 25 June 2025
PUB00496 GST listed services rules 27 June 2025

Consultations closing soon 

PUB00484: The Commissioner's duty of care and management - section 6A of the Tax Administration Act 1994

Closes on 26 May 2025

Public advice and guidance work programme 2025-26 

Each year the Tax Counsel Office prepares a programme of public guidance work for the following year.

If you are aware of any tax technical or interpretative issues you think we should publish guidance on, please let us know by 6 June 2025.

Before adding a suggestion to the work programme, we consider the importance of the issues involved, the level of uncertainty/ambiguity, the number of customers potentially affected, and the potential revenue implications.  Any relevant information you can provide about these factors is appreciated.
 
Find out more about how to make a suggestion.

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