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17 Feb 2023

Charities – business income exemption

This Issues Paper discusses the interpretative and practical issues a charity may face when applying s CW 42 to income it derives from a business carried out exclusively for charity. The matters discussed in this paper will be of particular interest to charities with charitable purposes in and outside New Zealand.

All legislative references are to the Income Tax Act 2007 unless otherwise stated.


This issues paper was released for public consultation. Consultation closed on 17 February 2023.

About issues papers

Inland Revenue’s Tax Counsel Office (Public Advice and Guidance) develops and publishes public statements interpreting the tax laws.

Where significant uncertainty exists, it helps us to hear from interested parties before we prepare a public statement. This generates discussion so we gain a better understanding of the issues, including practical concerns. An issues paper sets out our initial views on how the relevant tax laws may apply. If it results in the issue of a draft public statement, public consultation will occur in the usual manner.

Given that issues papers produced by the Tax Counsel Office represent our initial views only, taxation officers, taxpayers and practitioners must not rely on them. Only finalised public statements represent authoritative statements by Inland Revenue of its stance on the issues covered. 

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

Find out more about issues papers