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2011 media releases

Inland Revenue issues draft tax avoidance Interpretation Statement for consultation
19 December 2011

Inland Revenue has issued a draft Interpretation Statement about tax avoidance for public consultation.

Under sections BG 1 and GA 1 of the Income Tax Act, if an arrangement is a "tax avoidance arrangement", the Commissioner has powers to counteract any tax advantage that an individual or an entity has sought to gain under it.

Chief Tax Counsel, Martin Smith, said that the statement sets out the Commissioner's view of the principles to be applied in reaching a view on whether an arrangement is a "tax avoidance arrangement". 

"Tax planning including the use of alternative business structures does not necessarily constitute an avoidance arrangement."

"However, Inland Revenue does focus on cases where there are clear indicators and circumstances indicating that a taxpayer has entered into a tax avoidance arrangement.  The draft statement outlines and discusses in some depth the factors that have been highlighted by the Courts, and these are the types of factors that will be important in Inland Revenue's consideration of this issue".

Mr Smith said that the draft statement is particularly based upon the Supreme Court's judgments and approach to the law in the Ben Nevis and Penny and Hooper cases. 

"By issuing a framework and the principles for applying section BG 1, Inland Revenue is attempting to pull together what the Courts have been saying about the section, and provide greater clarity as to how to assess each case based on its particular facts and characteristics."  

Submissions will close at end of March and the statement is likely to be finalised in mid 2012.

The Interpretation Statement is available on the Inland Revenue website (keyword search "ins0121").

For further information:
David G. Miller
(04) 890 1743
(029) 890 1743
david.miller@ird.govt.nz

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Corporate Affairs
Inland Revenue

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Phone 04 890 1698 or email mediaqueries@ird.govt.nz
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Wellington 6140
New Zealand


Date published: 11 Jan 2012

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