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New Zealand: Draft guidance for implementing BEPS legislation

New Zealand: Draft guidance for BEPS legislation

The New Zealand Inland Revenue Department has requested comments on five draft “special reports” intended to provide guidance on how the tax agency would consider certain elements of a new tax law addressing base erosion and profit shifting (BEPS).


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The new tax law—Taxation (Neutralising Base Erosion and Profit Shifting) Act,  referred to as the “BEPS Tax Act”—was enacted in early July 2018 and contains various rules that affect New Zealand businesses that have cross-border dealings. 

These changes generally apply from income years beginning on or after 1 July 2018. Read TaxNewsFlash

Five draft special reports

The five draft special reports concern:  

  • Interest limitation
  • Hybrid and branch mismatch arrangements
  • Transfer pricing
  • Permanent establishment avoidance  
  • BEPS-related administrative measures 

The draft special reports offer examples intended to make the application of the new rules as clear as possible. Comments are due by 28 September 2018 and the final guidance is not due to be published until early 2019.


Read an August 2018 report [PDF 207 KB] prepared by the KPMG member firm in New Zealand

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