Product rulings: Product rulings 2004
Download product rulings for 2004
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)
- 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 3 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- occasionally, a ruling is withdrawn for one reason or another before its expiry date; the table below indicates that a ruling has been withdrawn only if the ruling would presently be current had it not been withdrawn.
Bursary payments - exempt income
Applicant: Royal New Zealand College of GPs
Under this ruling, payments made by the College to trainees are exempt income.
Ruling applies from: 1 January 2004 to 31 December 2006
BR Prd 04/14 - RTF format (113kb | 6 pages)
BR Prd 04/14 - PDF format (54kb | 6 pages)
Airpoints Dollars - accruing and redemption
Applicant: Air New Zealand
Under this ruling, no gross income arises to members of the Air New Zealand Airpoints Programme when they receive Airpoints Dollars or Rewards, and there is no FBT liability.
Ruling applies from: 3 November 2004 to 2 November 2007
BR Prd 04/13 - RTF format (114kb | 8 pages)
BR Prd 04/13 - PDF format (73kb | 8 pages)
Course participation payments - exempt income
Applicant: Royal NZ College of GPs
Under this ruling, payments to the Registraras are exempt income.
Ruling applies from: 1 January 2004 to 31 December 2009
BR Prd 04/12 - RTF format (112kb | 7 pages)
BR Prd 04/12 - PDF format (60kb | 7 pages)
Sponsorship expenditure - deductibility
Applicant: University of Otago Foundation Trust
Under this ruling, sponsorship expenditure will not be expenditure of a capital nature and will be an allowable deduction.
Ruling applies from: 30 June 2004 to 1 July 2007
BR Prd 04/11 - RTF format (64kb | 3 pages)
BR Prd 04/11 - PDF format (36kb | 3 pages)
Passive investment fund
Applicant: BNZ International Equity Index Fund
Under this ruling the Fund is a superannuation fund and a qualifying trust.
Ruling applies from: 1 July 2004 to 30 June 2007
BR Prd 04/10 - RTF format (393kb | 8 pages)
BR Prd 04/10 - PDF format (73kb | 8 pages)
Passive investment fund
Applicant: ASB NZ Shares Trust
Under this ruling income distributed by the Trustee will be treated as a dividend.
Ruling applies from: 1 July 2004 to 30 June 2007
BR Prd 04/09 - RTF format (117kb | 10 pages)
BR Prd 04/09 - PDF format (76kb | 10 pages)
Passive investment fund
Applicant: ASB - World Shares Trust
Under this ruling income distributed by the Trustee will be treated as a dividend.
Ruling applies from: 1 July 2004 to 30 June 2007
BR Prd 04/08 - RTF format (120kb | 10 pages)
BR Prd 04/08 - PDF format (82kb | 10 pages)
Passive investment fund
Applicant: Tortis International
Under this ruling income distributed by the Trustee will be treated as a dividend.
Ruling applies from: 1 July 2004 to 30 June 2007
BR Prd 04/07 - RTF format (400kb | 18 pages)
BR Prd 04/07 - PDF format (116kb | 18 pages)
Passive investment fund
Applicant: NZGT/NZGT30
Under this ruling the distribution of category A income to category A unit holders will be treated as a dividend.
Ruling applies from: 1 July 2004 to 30 June 2007
BR Prd 04/06 - RTF format (80kb | 5 pages)
BR Prd 04/06 - PDF format (48kb | 5 pages)
Olive grove investment - deductibility of expenditure
Applicant: Brooklyn Park Olive Groves
This ruling sets out the rules for deductibility of expenditure on the purchase of shares in an olive grove investment.
Ruling applies from: 1 July 2003 to 30 June 2006
BR Prd 04/05 - RTF format (230kb | 13 pages)
BR Prd 04/05 - PDF format (125kb | 13 pages)
Employee share scheme
Applicant: McBreen Jenkins
This ruling sets out the tax implications for employees of the McBreen Jenkins Construction Limited Employee Option Plan.
Ruling applies from: 15 March 2004 to 14 March 2009
BR Prd 04/04 - RTF format (123kb | 10 pages)
BR Prd 04/04 - PDF format (79kb | 10 pages)
GST - whether payable on grants
Applicant: Infrastructure Auckland
Under this ruling grant payments received by IA will not be subject to GST.
Ruling applies from: 5 May 2004 to 4 May 2009
BR Prd 04/03 - RTF format (114kb | 10 pages)
BR Prd 04/03 - PDF format (70kb | 10 pages)
Sale of forests
Applicant: Fletcher Challenge Forests
Under this ruling the return of capital will be excluded from the definition of "dividends", to the extent that it does not exceed teh "available subscribed capital".
Ruling applies from: 13 February 2004 to 31 March 2006
BR Prd 04/02 - RTF format (94kb | 4 pages)
BR Prd 04/02 - PDF format (46kb | 4 pages)
FBT value of vehicle in lease agreement
Applicant: Truck Leasing t/a Esanda
Under this ruling, the market value of a motor vehicle for FBT purposes is determined on the date on which each new 12-month lease commences.
Ruling applies from: 4 May 2004 to 3 May 2007
BR Prd 04/01 - RTF format (77kb | 5 pages)
BR Prd 04/01 - PDF format (48kb | 5 pages)
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Date published: 15 Jun 2007
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