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Technical tax area
Te wahi mo te take hangarau
Technical tax area: Product rulings

Download product rulings

We issue product rulings only if both the following conditions are met:

  • it is not feasible to seek a private ruling on the arrangement (this is generally because the identities of the other parties may not be known), and
  • the characteristics of the taxpayers who may enter into the arrangement do not affect the content of the ruling.

Product rulings are issued by the Office of the Chief Tax Counsel (OCTC) business group of Inland Revenue. If you have any inquiries about product rulings:

  • see A guide to binding rulings (IR715), or
  • contact us

The table below lists product rulings issued by year and number (BR Prd), with a brief description of the subject matter (earlier years will progressively be added).

Caution should be exercised when looking at these product rulings:

  • Product rulings apply only to the arrangement specified in the ruling. A general similarity to an arrangement will not necessarily lead to the same tax result.
  • Rulings generally expire after three years.
  • The table below does not indicate whether a ruling has expired (the expiry date of a ruling is set out in the text under the heading "The period for which this Ruling applies").
  • Occasionally, a ruling is withdrawn before its expiry date. The table below indicates that a ruling has been withdrawn only if the ruling would be current if it had not been withdrawn.


How the Income Tax Act 2007 applies to the raising of capital by Rabo Capital Securities Ltd

Applicant: Rabo Capital Securities Limited
This ruling applies to the raising of capital by Rabo Capital Securities Ltd via the sale of New Zealand dollar denominated, perpetual, non-cumulative, non-voting preference shares to the public.

Ruling applies from: 27 May 2009 to 30 June 2014

BR Prd 09/07 - RTF format (109kb | 9 pages)
BR Prd 09/07 - PDF format (71kb | 9 pages)


How the Income Tax Act 2007 and Goods and Services Tax Act 1985 applies to the engagement of metropolitan supervisors by Reach Media New Zealand Limited

Applicant: Reach Media New Zealand Limited
This ruling applies to the engagement of supervisors to provide supervisory services in metropolitan areas in relation to the delivery of unaddressed mail.

Ruling applies from: 1 July 2008 to 30 June 2012

BR Prd 09/06 - RTF format (83KB | 4 pages)
BR Prd 09/06 - PDF format (32KB | 4 pages)


How the Income Tax Act 2007 and Goods and Services Tax Act 1985 applies to the engagement of distributors by Reach Media New Zealand Limited

Applicant: Reach Media New Zealand Limited
This ruling applies to the engagement of distributors for the physical delivery of unaddressed mail to households and other premises throughout New Zealand.

Ruling applies from: 1 July 2008 to 30 June 2012

BR Prd 09/05 - RTF format (80KB | 4 pages)
BR Prd 09/05 - PDF format (33KB | 4 pages)


How the Income Tax Act 2007 and Goods and Services Tax Act 1985 applies to the engagement of country supervisors by Reach Media New Zealand Limited

Applicant: Reach Media New Zealand Limited
This ruling applies to the engagement of supervisors to provide supervisory services in country areas in relation to the delivery of unaddressed mail.

Ruling applies from: 1 July 2008 to 30 June 2012

BR Prd 09/04 - RTF format (85KB | 4 pages)
BR Prd 09/04 - PDF format (33KB | 4 pages)


How the Income Tax Act 2007 and Goods and Services Tax Act 1985 applies to the engagement of drivers by Reach Media New Zealand Limited

Applicant: Reach Media New Zealand Limited
This ruling applies to the engagement of drivers for the transport of unaddressed mail from Reach Media's premises to pre-determined drop-off locations.

Ruling applies from: 1 July 2008 to 30 June 2012

BR Prd 09/03 - RTF format (79KB | 4 pages)
BR Prd 09/03 - PDF format (27KB | 4 pages)


How the Income Tax Act 2007 applies to payments made to students by the New Zealand Maori Arts and Crafts Institute

Applicant: New Zealand Maori Arts and Crafts Institute
This ruling applies to scholarships provided by the New Zealand Maori Arts and Crafts Institute to students enrolled in a Diploma in Traditional Whakairo (Maori carving) course, for the purposes of covering student's living costs.

Ruling applies from: 6 November 2008 to 5 November 2013

BR Prd 09/01 - RTF format (118KB | 3 pages)
BR Prd 09/01 - PDF format (44KB | 3 pages)


How the Income Tax Act 2007 applies to the raising of capital by Bank of New Zealand and National Australia Bank

Applicant: BNZ Income Securities Limited
This ruling covers the raising of capital by Bank of New Zealand and National Australia Bank Limited. It covers the issue by BNZ Income Securities Limited of perpetual non-cumulative shares to the public, the loan of the proceeds from that issue to BNZ Income Management Limited, and the investment of those proceeds by BNZ Income Management Limited in perpetual preference shares issued by BNZ. This ruling is associated with Determination S14 (see accrual determinations for more information).

Ruling applies from: 28 March 2008 to 28 March 2013

BR Prd 09/02 - RTF format (180 kb | 10 pages)
BR Prd 09/02 - PDF format (120 kb | 10 pages)


How the Income Tax Act 2004 applies to the leasing of thoroughbred breeds of horse by New Zealand Bloodstock Leasing Limited

Applicant: New Zealand Bloodstock Leasing Limited
This ruling covers the leasing of a thoroughbred breed of horse by New Zealand Bloodstock Leasing Limited to customers for use in breeding bloodstock progeny.

Ruling applies from: 5 December 2007 to 5 December 2012

BR Prd 08/04 - RTF format (99 kb | 6 pages)
BR Prd 08/04 - PDF format (84 kb | 6 pages)


How the Goods and Services Tax Act 1985 applies to the development of software and provision of network services by Capital Market Solutions NZ Ltd

Applicant: Capital Market Solutions NZ Limited
This ruling deals with the supply of services relating to the development and maintenance of NOVA software and provision of network services by Capital Market Solutions to its New Zealand customers.

Ruling applies from: 1 March 2008 to 31 October 2011

BR Prd 08/03 - RTF format (209kb | 9 pages)
BR Prd 08/03 - PDF format (71kb | 9 pages)


How the Income Tax Act 2007 applies to the purchase and lease back of livestock by StockCo Ltd

Applicant: StockCo Limited
This ruling deals with the purchase and lease back of "specified or high-priced livestock" by StockCo Ltd for the purposes of the Income Tax Act 2007.

Ruling applies from: 1 April 2008 to 31 March 2011

BR Prd 08/02 - RTF format (141kb | 8 pages)
BR Prd 08/02 - PDF format (89kb | 8 pages)


How the tax law applies to the engagement of delivery drivers by Restaurant Brands Ltd

Applicant: Restaurant Brands Limited
This ruling deals with the engagement of delivery drivers by Restaurant Brands Limited for the purposes of the Income Tax Acts 2004 and 2007 and the GST Act 1985.

Ruling applies from: 26 October 2006 to 26 October 2009

BR Prd 08/01 - RTF format (122kb | 8 pages)
BR Prd 08/01 - PDF format (137kb | 8 pages)


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Other rulings by year

2009 | 2008 | 2007 | 2006 | 2005 | 2004 | 

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Date published: 15 Jun 2007

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