Product rulings: Product rulings 2009
Download product rulings for 2009
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- occasionally, a ruling is withdrawn for one reason or another before its expiry date; the table below indicates that a ruling has been withdrawn only if the ruling would presently be current had it not been withdrawn.
The Royal New Zealand College of General Practitioners
Applicant: The Royal New Zealand College of General Practitioners
The arrangement is the provision of monthly payments by the College to Trainees, for the Trainees' participation in the Postgraduate Rural General Practice Education Programme.
Ruling applies from: Ruling applies from: 1 January 2010 to 31 March 2015
BR Prd 09/11 - RTF format (85kb | 6 pages)
BR Prd 09/11 - PDF format (35kb | 6 pages)
The Royal New Zealand College of General Practitioners
Applicant: The Royal New Zealand College of General Practitioners
The arrangement is the provision of monthly payments by the College to Registrars, for the Registrars' participation in stage one of the General Practice Education Programme.
Ruling applies from: 1 January 2010 to 31 March 2015
BR Prd 09/10 - RTF format (112kb | 6 pages)
BR Prd 09/10 - PDF format (40kb | 6 pages)
BNZ Income Securities 2 Limited
Applicant: BNZ Income Securities 2 Limited
The arrangement is the raising of capital by Bank of New Zealand Limited and its parent company National Australia Bank Limited, and also involves the issue of perpetual non-cumulative shares and loan transactions with BNZ Income Management Limited.
Ruling applies from: 26 June 2009 to 30 June 2014.
BR Prd 09/12 - RTF format (512kb | 13 pages)
BR Prd 09/12 - PDF format (68kb | 13 pages)
Air New Zealand Limited
Applicant: Air New Zealand Limited
The Arrangement is the accruing by a Member of the Air New Zealand Airpoints Programme of Airpoints Dollars provided by Air New Zealand as a result of expenditure incurred by the Member's employer on the Member's work related travel and the redemption of those Airpoints Dollars for air travel and other rewards.
Ruling applies from: 1 April 2009 to 31 March 2014
BR Prd 09/09 - RTF format (66kb | 7 pages)
BR Prd 09/09 - PDF format (70kb | 7 pages)
Newmont Mining NZ Companies (Consolidated Group)
Applicant: Newmont Mining NZ Companies (Consolidated Group) ("Newmont")
The Arrangement is the payment to persons pursuant to the Amenity Effect Programme ("AEP").
Ruling applies from: 12 March 2009 to 31 March 2010
BR Prd 09/08 - RTF format (80kb | 2 pages)
BR Prd 09/08 - PDF format (13kb | 2 pages)
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)
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Date published: 18 Feb 2009
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