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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

TDS 25/20 Transfer of property between charitable trusts

07 Aug 2025 Technical decision summary / 2025
This item summarises a private ruling about whether the market value of properties and chattels transferred between charitable trusts is taxable when the transferors deregister as charitable entities.

IS 25/18 Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust

07 Aug 2025 Interpretation statements / 2025
This interpretation statement considers the income tax treatment of amounts of money or property that New Zealand tax residents receive from a person overseas, including through inheritance. It addresses how to determine whether the person who transfers the money or property is a trustee of a trust and when the resident taxpayer has derived beneficiary income or a taxable distribution from a foreign trust.

IS 25/18 FS Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust fact sheet

07 Aug 2025 Fact sheets / 2025

This fact sheet accompanies IS 25/18: Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust. It will be of interest to New Zealand tax residents who receive money or property from overseas that may possibly be taxable in New Zealand and to their tax advisors.

TDS 25/19 Company restructure for commercial and estate planning

04 Aug 2025 Technical decision summary / 2025
This item summarises a private ruling that considered whether a company restructure for commercial and estate planning is tax avoidance.

Volume 37 No 7 Tax information bulletin - August 2025

01 Aug 2025 TIB / Volume 37 - 2025

New legislation

  • Taxation (Budget Measures) Act 2025 commentary

Operational statements

  • OS 25/04: The Commissioner of Inland Revenue’s search powers
  • OS 25/05: Section 17B Notices

Question we've been asked

  • QB 25/17: Income tax: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset?

Case summaries

  • CSUM 25/10: High Court dismisses judicial review of decisions to decline proposals for relief under s 177 of the TAA
  • CSUM 25/11: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime

Technical decision summaries

  • TDS 25/15: GST – input tax deductions, grants, omitted sale
  • TDS 25/16: Charitable trust – transfer of assets

QB 25/19 GST listed services rules: When is a supply of listed services made through an electronic marketplace?

28 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) discusses one of the key requirements for when the GST listed services rules apply. That is, the supply must be made by an underlying supplier to a recipient through an electronic marketplace operator. It explains that this requirement is satisfied when the marketplace is involved in, and facilitates, supplies between underlying suppliers and recipients.

QB 25/20 GST listed services rules: How do the rules apply when there is a supply of listed services and other goods or services?

28 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked (QWBA) discusses some issues with identifying the relevant supplies for the GST listed services rules. It explains what listed services are and how to apply the GST listed services rules if a supply includes listed services with other goods or services.

TDS 25/18 Sale of intellectual property, shares and ongoing provision of services

25 Jul 2025 Technical decision summary / 2025
This item summarises a private ruling concerning a cross-border arrangement involving the sale of intellectual property, other assets, shares, and the provision of services between a New Zealand company and its offshore parent.

FDR 2025/05 Determination the fair dividend rate method may not be used to calculate FIF income by investors in the iShares Global Aggregate Bond ESG SRI UCITS ETF – EUR hedged (Accumulating) share class

17 Jul 2025 Determinations / International tax / Foreign investment funds / 2025
Any investment by a New Zealand resident investor in the EUR hedged (Accumulating) share class of the iShares Global Aggregate Bond ESG SRI UCITS ETF (ISIN IE000APK27S2), a sub-fund of iShares III Public Limited Company (iShares III), to which none of the exemptions in sections EX 29 to 43 of the Income Tax Act 2007 apply, is a type of attributing interest for which the investor may not use the fair dividend rate ("FDR") method to calculate foreign investment fund income for the interest when the investment is hedged to NZD by the New Zealand resident investor.

QB 25/18 Does GST apply to a deposit the seller retains in a cancelled land sale agreement?

15 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked explains the GST consequences when a land sale agreement is cancelled and the seller retains the deposit.