TDS 24/18 Restructuring a group of companies
The establishment of a limited partnership to hold the shares in a holding company. The long-form amalgamation of the holding company and one of its subsidiaries under Part 13 of the Companies Act 1993, with the subsidiary remaining as the amalgamated company. The distribution by the holding company of cash and shares in subsidiary companies on amalgamation as consideration for the cancellation of its shares.
Volume 36 No 9 TIB - October 2024
New legislation
- LI 2024/189 Tax Administration (GST Adjustment Rules) Modification Order 2024
Rulings
- BR Prd 24/02 and BR Prd 24/03: WorkRide Limited
Interpretation statement
- IS 24/07: Deductions for parties to employee share schemes
Commissioner’s statement
- CS 24/02: Withholding obligations arising in relation to transfer pricing arrangements
Question we’ve been asked
- QB 24/5: Do supplies of standing timber and other unsevered crops wholly or partly consist of land for the compulsory zero-rating rules?
Technical decision summary
- TDS 24/17: Deductibility of bonus payments
Case summary
- CSUM 24/06: High Court issues a 28-day temporary halt of Commissioner’s bankruptcy proceedings pending payment of sum
IS 24/08 Charities – Business income exemption
This interpretation statement considers what income is from a business and the extent to which business income a charitable entity derives is exempt from tax under s CW 42.
IS 24/08 FS 1 Income tax – Charities – Business income exemption - fact sheet
Volume 36 No 8 TIB - September 2024
New legislation
- SL 2024/154– Order in Council Double Tax Agreements (Slovak Republic) Order 2024
- SL 2024/153 – Order in Council Double Taxation Relief (Austria) Amendment Order 2024
Legislation and determinations
- DET 24/03: Determination under section RD 11(3) of the Income Tax Act 2007 of the amount of tax for a payment of a main benefit
Interpretation statements
- IS 24/05: Employer obligations for employee share scheme benefits paid in cash
- IS 24/06: PAYE – How an employer funds the tax cost on an employee share scheme benefit
Commissioner’s statement
- CS 24/01: Determining the “market value” of shares that an employee receives under an employee share scheme
Standard practice statements
- SPS 24/01: Requests to change a balance date
- SPS 24/02: Extension of time applications from customers without tax agents
Technical decision summaries
- TDS 24/15: GST – payment for participation in religious practice
- TDS 24/16: Look-through company election
CS 24/02 Withholding obligations arising in relation to transfer pricing arrangements
This Commissioner’s statement sets out the Commissioner’s position and operational approach in relation to the withholding obligations that may arise in relation to transfer pricing arrangements.
CSUM 24/05 High Court finds remediation work on rental property capital in nature
This was an application by Mr McGuire, the judgment debtor, to halt bankruptcy proceedings against him, brought by the Commissioner of Inland Revenue (the Commissioner) on 1 March 2023.
IS 24/07 Deductions for parties to employee share schemes
This interpretation statement considers what deductions employers can claim for income tax in relation to employee share schemes. It explains the need to satisfy the general permission and when the capital limitation might apply.
A trust is a creation of the law of equity and is not a legal entity distinct from its trustee. Instead, a trust is a fiduciary relationship where a trustee holds property for the benefit of beneficiaries or, where the trust is a charitable trust, for the specified charitable purposes. Although the trustee has legal ownership of the trust property, they hold it subject to the beneficial interests of the beneficiaries and must act in accordance with the terms of the trust and the Trusts Act 2019.
Reference | Title | Closes |
---|---|---|
ED0258 | The Commissioner of Inland Revenue’s search powers | 18 October 2024 |
ED0260 | Section 17B Notices | 18 October 2024 |
PUB00486 | GST treatment of fees paid in relation to managed funds | 25 October 2024 |
PUB00487 | Income tax – short-stay accommodation | 25 October 2024 |
PUB00461 | Income tax – arrangements involving tax losses carried forward under the business continuity rules | 01 November 2024 |
PUB00457 | INC – Company amalgamation rules | 01 November 2024 |
PUB00453 | Income tax and FBT - deducting costs of travel by motor vehicle between home and work | 06 November 2024 |
PUB00489 | How do the bright-line rollover relief provisions apply to transfers of residential land between associated persons? | 08 November 2024 |
ED0245 | Deduction notices | 15 November 2024 |
Consultations closing soon
The Commissioner of Inland Revenue's search powers and Section 17B Notices
Closes: 18 October 2024
Special Report - Tax Administration (GST Adjustment Rules) Modification Order 2024
This special report on our Tax Policy site provides early information about a modification made by Order in Council to the GST adjustment rules.