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 please 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 considering these product rulings:
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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.
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Rulings generally expire after three years.
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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- Occasionally, a ruling is withdrawn before its expiry date. The table below indicates that a ruling has been withdrawn only if the ruling would be current if it had not been withdrawn.
Telecom / Chorus demerger
Applicant: Telecom Corporation of New Zealand Limited
This product ruling applies to the demerger of Chorus Limited from Telecom so as to bring about the structural separation of the Telecom Group's network infrastructure businesses from its other retail-focussed businesses. This is in order to meet the independence requirement of the Ultra-Fast Broadband Initiative.
Ruling applies from: 1 July 2011 to 30 June 2014
BR Prd 11/05 - RTF format (427kb | 14 pages)
BR Prd 11/05 - PDF format (102kb | 14 pages)
Kiwibank Offset Mortgage
Applicant: Kiwibank Limited
This ruling applies to the Kiwibank Offset Mortgage product, to be offered by Kiwibank to its customers.
Ruling applies from: 27 May 2011 to 31 May 2016
BR Prd 11/04 - RTF format (91kb | 7 pages)
BR Prd 11/04 - PDF format (47kb | 7 pages)
Offering of Fly Buys points by Bank of New Zealand
Applicant: Bank of New Zealand
This ruling applies to the offering by Bank of New Zealand of Fly Buys points to Fly Buys members who invest in either the BNZ Term portfolio investment entity, or the BNZ Cash portfolio investment entity.
Ruling applies from: 23 September 2011 to 30 September 2014
BR Prd 11/03 - RTF format (104kb | 7 pages)
BR Prd 11/03 - PDF format (34kb | 7 pages)
Engagement of deliverers by PMP Distribution
Applicant: PMP Distribution Limited
This ruling applies to the engagement of deliverers by PMP Distribution Ltd for the delivery of unaddressed newspapers, leaflets, brochures, catalogues, advertising material, samples and other similar items to households and other premises.
Ruling applies from: 1 July 2010 to 30 June 2014
BR Prd 11/02 - RTF format (45.1kb | 2 pages)
BR Prd 11/02 - PDF format (19kb | 2 pages)
Deductibility of lease payments for customers of StockCo Limited
Applicant: StockCo Limited
The arrangement covered by this ruling is a livestock lease transaction, under which StockCo Ltd leases livestock to a farmer (which may have been purchased from the farmer), and under which StockCo Ltd will receive a predetermined estimated market price on the sale of the livestock (whether to the farmer or to a third party) at the end of the lease.
Ruling applies from: 1 April 2011 to 31 March 2016
BR Prd 11/01 - RTF format (127kb | 9 pages)
BR Prd 11/01 - PDF format (55kb | 9 pages)
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Date published: 06 Jul 2011
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