New Zealand: Consultation on implementation of Pillar Two rules
Feedback requested on whether and how to implement the Pillar Two rules
Feedback requested on whether and how to implement the Pillar Two rules
Inland Revenue released a consultation document [PDF 1.6 MB] requesting feedback on whether and how New Zealand might implement the Pillar Two rules of the OECD/G20 Inclusive Framework’s proposed solution to the tax challenges arising from digitalisation of the economy. The rules under Pillar Two would establish a global minimum tax of 15% for multinational enterprises with a turnover of at least €750 million, effective from 2023.
The consultation document specifically requests feedback on the following issues:
- Whether New Zealand needs to adopt the global anti-base erosion (GloBE) rules, assuming that a critical mass of other countries also does so
- Whether New Zealand needs to apply the income inclusion rule (IIR) to New Zealand source income of in-scope multinationals, by way of a domestic minimum top-up tax
- When any adoption should be effective, particularly in relation to the IIR
- How best to translate the rules into New Zealand law
- What areas of uncertainty there may be in applying the rules to New Zealand tax law, and how to resolve these
- Whether tax paid to the New Zealand government under the rules should give rise to imputation credits
- Administrative aspects, for instance return filing and timing of payments
Comments are due 1 July 2022.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.