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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 25/17 Application of schedular payment rules

11 Jul 2025 Technical decision summary / 2025
This item summarises a private ruling about directorship services payments to non-residents and whether they are schedular payments.

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

11 Jul 2025 Questions we've been asked / 2025
This question we’ve been asked is about whether a taxpayer can deduct for income tax purposes the amount of expenditure they have incurred to repair a capital asset that they have recently acquired.  The repairs in question are those that essential so that the taxpayer can use it in their business or income-earning activity.

Volume 37 No 6 Tax information bulletin - July 2025

01 Jul 2025 TIB / Volume 37 - 2025

Determinations

  • NAMV 2025: National Average Market Values of Specified Livestock Determination 2025
  • OS 19 04 (KM 2025): Kilometre rates for the business use of vehicles for the 2025 income year
  • 2025 Consumers Price Index adjustment to standard-cost amounts for household services (childcare, boarding services, or short-stay accommodation)
  • 2025 CPI adjustment to Operational Statement OS 19/03: Square metre rate for the dual use of premises
  • Det 25/02: Determination of expenditure incurred relating to payments made by New Zealand Clinical Research to volunteers
  • Det 25/03: Determination of amount of a particular payment (being per diem allowances paid in the screen production industry) that shall be regarded as expenditure incurred relating to those payments

Ruling

  • BR Prd 25/03: Extraordinary Pay Limited

Interpretation statements

  • IS 25/16: Tax residence
  • IS 25/17: Tax residence – government service rule

Question we’ve been asked

  • QB 25/16: Income tax – How do the income tax rules apply when a close company provides short-stay
    accommodation?

Case summaries

  • CSUM 25/08: Absence of evidence makes it impossible to prove nexus with the expenditure and the claimed deductions
  • CSUM 25/09: Lack of complete financial records secures TCRA win for the Commissioner in major income suppression case

Technical decision summaries

  • TDS 25/13: Income tax – land transferred within a consolidated tax group
  • TDS 25/14: Business restructure

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

30 Jun 2025 Case summaries / 2025
The Court of Appeal granted the COP’s appeal, agreeing with the COP and CIR that where tax has been evaded and not subsequently paid to the CIR, the tax evader has benefited from significant criminal activity, and a profit forfeiture order should be made. The court rejected the view that the CIR’s ability to recover unpaid tax means there can be no benefit to the offender.

CSUM 25/10 High Court dismisses judicial review of decisions to decline proposals for relief under s 177 of the TAA

30 Jun 2025 Case summaries / 2025
This was a judicial review case. The applicants challenge decisions of the Commissioner to decline proposals for relief under s 177 of the Tax Administration Act 1994 (the TAA).  At issue is the interpretation of provisions of the TAA and the Commissioner’s obligation to collect the highest net revenue that is practicable within the law.

OS 25/04 The Commissioner of Inland Revenue’s search powers

27 Jun 2025 Operational statements / 2025
This operational statement outlines the procedures the Commissioner of Inland Revenue will generally follow when exercising the Commissioner’s search powers under ss 17, 17C and 17D of the Tax Administration Act 1994 and the Search and Surveillance Act 2012.

OS 25/05 Section 17B Notices

26 Jun 2025 Operational statements / 2025
This operational statement outlines the procedures the Commissioner will generally follow when issuing notices, including to third parties, under s 17B of the Tax Administration Act 1994. Section 17B, which relates to information demands, contains one of the Commissioner’s information-gathering powers. The Commissioner can use other information-gathering powers (such as s 17) in conjunction with s 17B, but they are not discussed in this statement.

TDS 25/16 Charitable trust – transfer of assets

26 Jun 2025 Technical decision summary / 2025
This item summarises a private ruling that addressed income tax issues arising from the transfer of assets from a charitable trust.

TDS 25/15 GST – input tax deductions, grants, omitted sale

12 Jun 2025 Technical decision summary / 2025
GST – input tax deductions, grants, omitted sale

DET 25/03 Determination of amount of a particular payment (being per diem allowances paid in the screen production industry) that shall be regarded as expenditure incurred relating to those payments

11 Jun 2025 Determinations / Miscellaneous / 2025

This determination applies to per diem payments.  It sets out the amount regarded as expenditure incurred in the production of particular schedular payments when those payments are per diem allowances paid to contractors/entertainers working in the Screen Production Industry in New Zealand.

Reference Title Closes
PUB00497 Student Loans – Overseas borrowers and their obligations 18 July 2025