Archived issues papers

What is a Tax Counsel Office issues paper?

At the Tax Counsel Office we develop and publish public statements that interpret the current tax laws. Where sufficient uncertainty exists, it helps us to hear from interested parties before we prepare any public statement. An issues paper sets out Inland Revenue’s initial views on how the relevant tax laws apply and requests feedback from interested parties. An issues paper is intended to stimulate discussion and allows us to gain a better understanding of the issues, including practical concerns affecting taxpayers.

What is the status of an issues paper?

Issues papers produced by the Tax Counsel Office represent the Inland Revenue’s initial views only. Taxation officers, taxpayers or practitioners may not rely on issues papers. Only finalised public statements represent Inland Revenue’s authoritative view on the issues covered.

Any views presented in an issues paper do not change the Commissioner’s current position or practices.


Table of issues reports
Number  Name   Date 
 IRRUIP13  Consequences of GST group registration  1 February 2019
 IRRUIP11  Whether remuneration paid to an employee in cryptocurrency is subject to PAYE or FBT  20 June 2018
 IRRUIP10  Income tax treatment of software development expenditure  25 August 2016
 IRRUIP9  Donee organisations – clarifying when funds are applied wholly or mainly to specified purposes within New Zealand  24 June 2016
 IRRUIP8  Unit trusts – whether more than one unit holder is required   10 March 2015
 IRRUIP7  Bodies corporate – GST registration   1 June 2013
 IRRUIP5  Interest deductibility in certain arrangements  31 July 2002
 IRRUIP4  The public benefit test  2 February 2000
 IRRUIP2  Implications of the Mitsubishi Decision   10 December 1996