New Zealand Seeks For Public Feedback On Draft BEPS Guidance

; posted on
August 28th, 2018

New Zealand reached out to the public for feedback on draft BEPS Guidance material issued at the same day to improve the content and presentation of the material. Based on the comments received, a clear and understandable guidance will be finalised in early 2019.


The Taxation (Neutralising Base Erosion and Profit Shifting) Act received the royal assent on June 27, 2018, which introduces amendments to the Income Tax Act 2017 and the Tax Administration Act 1994. In this Taxation Act, new measures and rules are included to counter the particular BEPS strategies observed in New Zealand. Following the enactment of the new Taxation Act, this draft guidance aims to give guidance to help taxpayers comply with the new legislation.

New Rules Covered in This Guidance

The draft guidance contains five draft special reports on interest limitation rules, hybrid and branch mismatch arrangements, transfer pricing rules, permanent establishment anti-avoidance rules and administrative measures. These reports show the form of the guidance, the direction it takes and the level of detail, which allows taxpayers to gauge for themselves in what areas more detailed explanation is required.

Any comments should be sent no later than 28 September 2018*.

Sources: Inland Revenue – BEPS, * Inland Revenue – Public Feedback

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