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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

BR Prd 25/05 Ministry of Education

06 Nov 2025 Rulings / Product / 2025

The Arrangement is the payment of bursaries that Initial Teacher Education (ITE) providers make to eligible student teachers under the School Onsite Training Programme. To be eligible, student teachers must be hosted in schools 3 days a week while completing their 1-year graduate or postgraduate ITE programme, approved by the Teaching Council, that will lead to teacher registration.

The Ministry of Education funds the bursary payments that the ITE providers make.

To the extent that a bursary payment an ITE provider makes to a student teacher under the Arrangement is income, it is exempt income of the student teacher under s CW 36 of the Income Tax Act 2007.

BR Prd 25/06 Ministry of Education

06 Nov 2025 Rulings / Product / 2025

The Arrangement is the payment of bursaries that the Ministry of Education makes to eligible student teachers under the Go Rural: Isolated Placements Fund. The bursaries are awarded to student teachers who are hosted in an isolated or rural, state or state-integrated school while completing their Initial Teacher Education programme that is Teaching Council approved.

The Ministry of Education funds the bursaries.

To the extent that a bursary payment the Ministry of Education makes to a student teacher under the Arrangement is income, it is exempt income of the student teacher under s CW 36 of the Income Tax Act 2007.

Volume 37 No 10 Tax Information Bulletin November 2025

03 Nov 2025 TIB / Volume 37 - 2025

New legislation

  • Public Act 2025 No 50: Income Tax (FamilyBoost) Amendment Act 2025

Determination

  • S65: Spreading method to be used for some electricity price contracts for difference

Standard practice statement

  • Notice of withdrawal: Imaging of electronic storage media

Interpretation statement

  • IS 25/21: GST – taxable activity

Case Summary

  • CSUM 25/12: High Court refuses to grant stay of liquidation pending outcome of judicial review proceeding

Technical decision summary

  • TDS 25/23: Disposal of cryptoassets

TDS 25/26 How does the business continuity test apply to a consolidated group?

28 Oct 2025 Technical decision summary / 2025
This item summarises a private ruling about the exit of two company subsidiaries from a consolidated group and the sale of a third subsidiary (the sole remaining member of the consolidated group) to a third party. It considers the business continuity test and whether a specific anti-avoidance provision applies.

TDS 25/25 Restructure and transfer of shares

24 Oct 2025 Technical decision summary / 2025
This item summarises a private ruling about the transfer of shares between companies within a group as part of a restructure and whether any future sale of the shares is taxable.

QB 25/21 Income tax – Public private partnership projects and business continuity test for losses

23 Oct 2025 Questions we've been asked / 2025
This QWBA confirms that s IB 3(2)(c), which is a central requirement of the business continuity test, is not breached when a standard PPP project transitions from the design and construction phase to the operation and maintenance phase. Accordingly, a corporate PPP contractor may generally rely on the business continuity test to carry forward losses incurred during the design and construction phase, even if shareholder continuity is breached during that phase.

TDS 25/24 The supply of accommodation in a serviced apartment

22 Oct 2025 Technical decision summary / 2025
This item summarises a private ruling about the supply of accommodation in a retirement village that includes the provision of mandatory services and whether this constitutes the taxable supply of accommodation in a commercial dwelling.

CSUM 25/12 High Court refuses to grant stay of liquidation pending outcome of judicial review proceeding

17 Oct 2025 Case summaries / 2025

The Commissioner commenced liquidation proceedings against KD Transport Limited (KD). KD requested relief under s 177 of the TAA which the Commissioner declined. KD sought judicial review of the Commissioner’s decision declining its proposal for relief and also applied to stay the liquidation proceeding, pending determination of its judicial review application. The stay application needed an extension of time as it was made outside the five working day period prescribed in the High Court Rules. The application for an extension of time was dismissed, and the Associate Judge made an order liquidating KD.

Tax Information Bulletin - Vol 37 No 10, November 2025

TDS 25/23 Disposal of cryptoassets

09 Oct 2025 Technical decision summary / 2025

This item summarises an adjudication about the acquisition and disposal of cryptoassets (including staking rewards) and whether the amounts derived are income.

Tax Information Bulletin - Vol 37 No 10, November 2025

IS 25/21 GST - taxable activity

08 Oct 2025 Interpretation statements / 2025

This interpretation statement sets out the Commissioner’s view on the meaning of “taxable activity”.  The Commissioner has discussed this concept in numerous public items, but generally in a specific context such as subdivisions of land, horse racing or horse breeding.  This statement is of more general application. It replaces GST on disposal of assets used principally in making exempt supplies Tax Information Bulletin Vol 1, No 7 (January 1990), 6 and Whether an activity is a GST taxable activity or a hobby Tax Information Bulletin Vol 6, No 14 (June 1995), 5.

Tax Information Bulletin - Vol 37 No 10, November 2025

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Consultations closing soon

PUB00509: Income tax implications of providing sponsorship

Consultation closes: 21 November 2025