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Public consultation
Te runanga tumatanui

Public consultation

Consultation is important to us and we encourage you to have your say about our tax rulings and other documents.

On this page:

About the consultation process

Inland Revenue produces a number of statements and rulings to explain to taxpayers and their agents how taxation laws affect them. These are produced by the Office of the Chief Tax Counsel (OCTC) and Legal and Technical Services business groups of Inland Revenue. We are keen to produce items that accurately and fairly reflect taxation legislation and are useful to taxpayers and their advisors. Your feedback, as a user of that legislation, is highly valued.

You can have your say by providing us with comment on the technical and/or commercial aspects of the drafts. We will acknowledge receipt of your comments immediately, and reply in more detail to you before the item is finalised.

Drafts currently available for consultation are listed below and can be downloaded until the comment deadline. New drafts will be added as they become available.

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You can subscribe to receive an email notification when exposure drafts on proposed tax rulings are available for comment.

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For information about proposed changes to tax law visit the Policy Advice Division website.

Looking for final items?

Final items can be found in our technical tax area, and using the links below:

Draft items

Let us know what you think about our drafts. Are they technically accurate? Do they fairly reflect taxation legislation? Are they in line with commercial reality and useful in practical situations?


Income Tax - Meaning Of "Excessive Remuneration" And "Excessive Profits Or Losses" Paid Or Allocated To Relatives, Partners, Shareholders Or Directors

This draft Question We've Been Asked considers the question "When is the payment of remuneration or allocation of profits or losses considered to be excessive for the purposes of ss GB 23 to GB 25B?". It concludes that the payment of remuneration and allocation of a partnership's profits or losses must be reasonable. This QWBA updates and replaces a number of items.

Comment deadline: 8 August 2014

QWB0118 - RTF format (350kb | 12 pages)
QWB0118 - PDF format (130kb | 12 pages)

Income tax: Foreign tax credits for amounts withheld from United Kingdom pensions

This draft Question We've Been Asked considers whether a person can claim a foreign tax credit in New Zealand for amounts withheld in the United Kingdom on their pension payments. The item concludes that a person can only claim a foreign tax credit if they have paid foreign income tax. The United Kingdom does not have the right to tax a pension payment made to a New Zealand tax resident so an amount withheld is not foreign income tax. As a result, a person cannot claim a foreign tax credit in New Zealand for the amounts withheld by their United Kingdom pension provider.

Comment deadline: 8 August 2014

QWB0128 - RTF format (228kb | 12 pages)
QWB0128 - PDF format (135kb | 12 pages)

Operational approach on foreign tax credits for amounts withheld from United Kingdom pensions

The Commissioner has released a draft QWBA (QWBA0128) on foreign tax credits for amounts withheld from United Kingdom pensions for consultation. The Commissioner’s current operational approach to foreign tax credits for amounts withheld from United Kingdom pensions is outlined in this operational position. The purpose of the operational position is to inform taxpayers of the operational approach being adopted by the Commissioner. It is not being consulted on.

Comment deadline:

Operational position - RTF format (56kb | 2 pages)
Operational position - PDF format (40kb | 2 pages)

Payments Made by Parents or Guardians of Students to State Schools - GST Treatment

Like expired public rulings BR Pub 09/01 and BR Pub 03/04, this draft ruling addresses the GST treatment of payments made by the parents or guardians of students (other than international students) who are enrolled at state and state-integrated schools to the Boards of Trustees of such schools.

The draft ruling does not reflect any material change in the Commissioner's position on the GST treatment of payments made by parents to state and state-integrated schools. However, aspects of the draft ruling have been updated with assistance from the Ministry of Education to reflect their advice to school communities in revised Education circular 2013/06 - Payments by parents of students in state and state-integrated schools issued on 13 June 2013.

Comment deadline: 8 August 2014

XPB0051 - RTF format (283kb | 19 pages)
XPB0051 - PDF format (240kb | 19 pages)

You can email your comments to us at  This email address is only for providing feedback on public drafts.

For all other feedback, please use our Comments and feedback form

If you wish to post us your comments, send them to:

Team Manager, Technical Services
Office of the Chief Tax Counsel
National Office
Inland Revenue Department
PO Box 2198


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Date published: 11 Jun 2013

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