New Zealand: BEPS implementing legislation - KPMG Global
Share with your friends

New Zealand: BEPS implementing legislation would affect related-party loans

New Zealand: BEPS implementing legislation

A bill concerning base erosion and profit shifting (BEPS) has been introduced in New Zealand that would implement the government’s policies concerning BEPS matters.


Related content

There are provisions in the bill that would

  • Reduce interest rates allowed on inbound related-party loans
  • Narrow thin capitalisation “safe harbour” protection
  • Revise the transfer pricing rules to expand the authority of the Inland Revenue
  • Broaden the permanent establishment rules (including a new avoidance rule) 
  • Deny deductions and subject income to tax in relation to “hybrid” instruments and entities


The bill has been referred to the Finance and Expenditure Select Committee for consideration and public submissions. While it is due to be reported back by 12 June 2018, the bill’s proposals generally would be effective for income years beginning on or after 1 July 2018.


Read a December 2017 report [PDF 193 KB] prepared by the KPMG member firm in New Zealand

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in 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 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


Request for proposal