Volume 37 No 5 TIB - June 2025
New legislation
- Public Act 2025 No 09: Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025
- SL 2025/64: Income Tax (Fringe Benefit Tax, Interest on Loans) Amendment Regulations 2025
- SL 2025/65: Taxation (Use of Money Interest Rates) Amendment Regulations 2025
Operational statements
- OS 25/03: Authority to Act for Tax Agents, Representatives and Nominated Persons: Access to a Client’s Inland Revenue Information
Interpretation statements
- IS 25/14: Income tax – arrangements involving tax losses carried forward under the business continuity rules
- IS 25/15: Look-through companies and disposal of residential land under the bright-line test
Questions we’ve been asked
- QB 25/07: What is the income tax treatment of gift cards and products provided as trade rebates or promotions?
- QB 25/08: When is land acquired for a purpose or with an intention of disposal so that the amount derived from the sale is income?
- QB 25/09: When do I have a “regular pattern” of transactions that prevents me from using exclusions from the land sale rules for my residence or for my main home?
- QB 25/10: On what date is a person treated as acquiring land for the purposes of the land sale rules?
- QB 25/11: When is the bright-line start date for the 2-year bright-line test?
- QB 25/12: How does the bright-line test apply to the sale of a subdivided section?
- QB 25/13: When is the sale of a lifestyle block excluded from the bright-line test?
- QB 25/14: When does the business premises exclusion to the bright-line test apply?
- QB 25/15: How do the bright-line rollover relief provisions apply to transfers of residential land between associated persons?
Case summaries
- CSUM 25/05: NZTCRA rejects argument that an interest amount paid under a relationship property agreement was deductible as an expense under the Income Tax Act 2007
- CSUM 25/06: NZTCRA finds work to convert retail space to office space in commercial building was capital in nature
- CSUM 25/07: NZTCRA finds remediation work on unit was capital in nature
Technical decision summary
- TDS 25/08: Disposal of shares following amalgamation
- TDS 25/09: Distribution and resettlement of trusts
- TDS 25/10: Source of income and foreign tax credits
- TDS 25/11: Deductions, zero-rating and shortfall penalties
- TDS 25/12: Deductions and shortfall penalties
NAMV 2025 National Average Market Values of Specified Livestock Determination 2025
TDS 25/13 Income tax - land transferred within a consolidated tax group
IS 25/16 Tax residence
IS 25/17 Tax residence – government service rule
IS 25/16 FS 3 Tax residence and trusts fact sheet
IS 25/16 FS 2 Tax residence – companies fact sheet
IS 25/16 FS 1 Tax residence – individuals fact sheet
BR Prd 25/03 Extraordinary Pay Limited
Reference | Title | Closes |
---|---|---|
PUB00469 | Income Tax – Whether an off-market share cancellation is made in lieu of the payment of a dividend | 03 June 2025 |
2025 26 work programme | Public advice and guidance work programme 2025-26 | 06 June 2025 |
ED0259 | Tax on any fees paid to a member of a board, committee, panel, review group or task force | 11 June 2025 |
PUB00494 | Income tax – Whether money or property received by New Zealand tax residents from overseas is income from a foreign trust | 19 June 2025 |
ED0265 | Mutual transactions of associations (including clubs and societies) | 25 June 2025 |
PUB00496 | GST listed services rules | 27 June 2025 |
Consultations closing soon
PUB00469: Income Tax - Whether an off-market share cancellation is made in lieu of the payment and dividend
Closes on 3 June 2025
Public advice and guidance work programme 2025-26
Each year the Tax Counsel Office prepares a programme of public guidance work for the following year.
If you are aware of any tax technical or interpretative issues you think we should publish guidance on, please let us know by 6 June 2025.
Before adding a suggestion to the work programme, we consider the importance of the issues involved, the level of uncertainty/ambiguity, the number of customers potentially affected, and the potential revenue implications. Any relevant information you can provide about these factors is appreciated.
Find out more about how to make a suggestion.