Notifying Commissioner of change to the attributable FIF income method

2012 legislation requires taxpayers changing to the attributable FIF income method to give notice to the CIR before the end of the first income year of the change.

Section EX 62 of the Income Tax Act 2007

The branch equivalent and accounting profits methods of calculating a person's foreign investment fund (FIF) income have been repealed for income years beginning on or after 1 July 2011. The new attributable FIF income method applies from the same date. These changes were included in the Taxation (International Investment and Remedial Matters) Act 2012.

Taxpayers who would like change from another FIF calculation method to the attributable FIF income method will generally be required to give notice to the Commissioner before the end of the first income year or accounting period for which the change is to take effect (for further details refer to the recently amended section EX 62 of the Income Tax Act 2007).

This notice can be a declaration that they are changing their calculation method due to the branch equivalent or accounting profits methods being repealed. The declaration can be emailed to FIFnotice@ird.govt.nz. Taxpayers who do not make the election will generally default to the fair dividend rate calculation method.