Product rulings: Product rulings 2005
Download product rulings for 2005
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- occasionally, a ruling is withdrawn for one reason or another before its expiry date; the table below indicates that a ruling has been withdrawn only if the ruling would presently be current had it not been withdrawn.
Bonus shares issue
Applicant: SkyCity Consolidated Group
Under this ruling, where there is an option to redeem the shares and the shareholders elect to retain the shares and then sell them, the bonus is a non-taxable bonus issue and does not constitute dividends. Amounts derived on sale of the bonus shares are not gross income for certain shareholders.
Ruling applies from: 5 December 2005 to 31 March 2009
BR Prd 05/09 - RTF format (103kb | 7 pages)
BR Prd 05/09 - PDF format (60kb | 7 pages)
Bonus shares issue
Applicant: SkyCity Consolidated Group
Under this ruling, where there is an option to redeem the shares and the shareholders elect to redeem them, the bonus is a non-taxable bonus issue and does not constitute dividends. Amounts received in redemption are dividends and imputation credits may attach.
Ruling applies from: 5 December 2005 to 31 March 2009
BR Prd 05/08 - RTF format (106kb | 7 pages)
BR Prd 05/08 - PDF format (60kb | 7 pages)
Bonus shares issue
Applicant: SkyCity Consolidated Group
Under this ruling, where there is an option to redeem the shares and the shareholders elect to retain them, the bonus is a non-taxable bonus issue and does not constitute dividends.
Ruling applies from: 5 December 2005 to 31 March 2009
BR Prd 05/07 - RTF format (107kb | 6 pages)
BR Prd 05/07 - PDF format (55kb | 6 pages)
Passive investment fund
Applicant: NZGT/AMP Superannuation World Index Fund
Under this ruling any amounts (including securities) received by members as a result of redemption of units in the fund will not be income of the member.
Ruling applies from: 1 October 2005 to 30 September 2008
BR Prd 05/06 - RTF format (128kb | 10 pages)
BR Prd 05/06 - PDF format (84kb | 10 pages)
Passive investment fund
Applicant: NZGT/AMP Superannuation Tracker Fund
Under this ruling the cost of securities acquired by a member on redemption of units in the fund it the market value of those securities on the date the member acquires the securities.
Ruling applies from: 1 October 2005 to 30 September 2008
BR Prd 05/05 - RTF format (129kb | 10 pages)
BR Prd 05/05 - PDF format (97kb | 10 pages)
Bloodstock leasing
Applicant: New Zealand Bloodstock Leasing Ltd
Under this ruling bloodstock lease payments are allowable deductions under section BD 2(1)(b) and are not excluded from being deductible under section BD 2(2)(e) of the Income Tax Act 1994.
Ruling applies from: 10 February 2005 to 4 December 2007
BR Prd 05/04 - RTF format (67kb | 4 pages)
BR Prd 05/04 - PDF format (39kb | 4 pages)
Bloodstock leasing
Applicant: New Zealand Bloodstock Leasing Ltd
Under this ruling bloodstock lease payments are allowable deductions under section BD 2(1)(b) and are not excluded from being deductible under section BD 2(2)(e) of the Income Tax Act 1994.
Ruling applies from: 5 December 2002 to 9 February 2005
BR Prd 05/03 - RTF format (67kb | 4 pages)
BR Prd 05/03 - PDF format (39kb | 4 pages)
Wholesale superannuation fund
Applicant: BNZI/BNZ 25 NZ Equity Index Fund
Under this ruling, amounts derived by investors from withdrawals from a wholesale superannuation fund - the BNZ 25 NZ Equity Index Fund - are not income under section HH 3(5) of the Income Tax Act 2004.
Ruling applies from: 5 December 2002 to 9 February 2005
BR Prd 05/02 - RTF format (67kb | 4 pages)
BR Prd 05/02 - PDF format (38kb | 4 pages)
Passive investment fund
Applicant: NZGT/AMP Superannuation Tracker Fund
Under this ruling any amount including securities received by members as a result of redemption of units in the AMP Superannuation Tracker Fund will not be gross income.
Ruling applies from: 31 January 2005 to 30 January 2008
BR Prd 05/01 - RTF format (154kb | 11 pages)
BR Prd 05/01 - PDF format (96kb | 11 pages)
Microsoft Word Viewer 2003 can be used to access .rtf (Rich Text Format) files.
Download Acrobat Reader to view PDF files
Report an accessibility problem for this page
Date published: 15 Jun 2007
Back to top
