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CSUM 25/05
Issued
17 Apr 2025
Decision
17 Apr 2025
Appeal Status
Pending

NZTCRA rejects argument that an interest amount paid under a relationship property agreement was deductible as an expense under the Income Tax Act 2007

Mr A sought to deduct interest expenses of $18,069.31 in his 2016 income tax return. This amount related to interest Mr A was required to pay his ex-wife under a relationship property agreement. The Authority held there was an insufficient nexus between the interest payments and Mr A’s assessable income and disallowed the deduction.

Tax Information Bulletin - Vol 37 No 5, June 2025

Case
A v CIR [2025] NZTCRA 02

Income Tax Act 2007, ss DB 6, DA 1, and DA 2(2)

Public Trustee v Commissioner of Taxes [1938] NZLR 436 (CA)
Williams v Commissioner of Inland Revenue (1988) 10 NZTC 5,078 (HC)
Fahey v MSD Speirs Ltd [1975] 1 NZLR 240 (PC)
Re Securitibank Ltd (No 2) [1978] 2 NZLR 136 (CA)
Colonial Mutual Life Assurance Society Ltd v Commissioner of Inland Revenue (2000) 19 NZTC 15,614 (CA)
Pacific Rendezvous Ltd v Commissioner of Inland Revenue [1986] 2 NZLR 567 (CA)
Eggers v Commissioner of Inland Revenue [1988] 2 NZLR 365 (CA)
Commissioner of Inland Revenue v Brierley [1990] 3 NZLR 303 (CA)
Reid v Commissioner of Inland Revenue (1990) 12 NZTC 7,153 (HC)
Commissioner of Inland Revenue v Haenga [1986] 1 NZLR 119 (CA)