The use of a New Zealand subsidiary to provide services to an overseas parent company. Whether the overseas parent company had a permanent establishment in New Zealand.

Commissioner’s discretion; GST: voluntary registration, backdating registration

This determination establishes the national average market value (NAMV) of specified livestock for 2024.

This determination relates to the financial arrangement spreading method to be used by a company (Company A) to return income and expenditure in relation to certain off-market contracts for difference (CFDs) in respect of the wholesale price of electricity.

This determination sets criteria for when a person who supplies accommodation through an electronic marketplace (an underlying supplier) can enter into an opt-out agreement with the operator of an electronic marketplace. The determination is made under section 60C(2BC) of the Goods and Services Tax Act 1985. 

The determination applies on and from 21 May 2024 for taxable periods starting on or after 1 April 2024 and ending on or before 31 March 2025. 

Income tax: Disposal of personal property, income vs capital; tax avoidance

New legislation

• Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Act 2024

Determinations

• DET 24/01: Amortisation rates for listed horticultural plants 
• FDR 2024/01: A type of attributing interest in a foreign investment fund for which a person may not use the fair dividend rate method (Wellington Management Funds (Ireland) PLC - Wellington Global Impact Bond Fund NZD Class)
• DEP111: Tax Depreciation Rate for horticulture LED grow light systems
• CFC 2024/01: Non-attributing active insurance CFC status Tower Limited
• CFC 2024/02: Non-attributing active insurance CFC status Tower Limited
• CFC 2024/03: Non-attributing active insurance CFC status Tower Limited
• CFC 2024/04: Non-attributing active insurance CFC status Tower Limited
• CFC 2024/05: Non-attributing active insurance CFC status Tower Limited
• CFC 2024/06: Non-attributing active insurance CFC status Tower Limited

Interpretation statements

• IS 24/02: GST – Grouping for companies
• IS 24/03: GST – Who can group register?

Case summary

• CSUM 24/02: Taxpayer challenge to timeliness of Commissioner’s Statement of Position (CSOP) dismissed by TRA

Technical decision summary

• TDS 24/04: Receipt of a one-off payment 
• TDS 24/05: Sale of bare land when intended for a subdivision

Income tax: Employee share scheme; share scheme taxing date

Income tax: Suppressed income; GST: Input tax deductions, taxable activity; TAA: Shortfall penalties.

A number of items have been published by the Commissioner on the topic of International Tax. This overview sets out these items, organised by topic.