Technical tax area: Public rulings
Inland Revenue issues public rulings to interpret how a tax law applies to taxpayers and specific types of arrangements. Taxpayers whose circumstances match those in a ruling may apply it, but are not obliged to do so.
If you calculate your tax liability according to an applicable public binding ruling, we must assess your tax according to that ruling. A public ruling applies only to the particular taxation law and arrangement set out in the ruling, and only for a specified period. If there is any material difference between the facts in the ruling and your actual arrangement, the ruling does not apply.
All the public rulings issued to date for the current year are displayed here by year, number (BR Pub), title, and status.
Income tax - treatment of a subdivision of shares under section CB 4 and Income tax - treatment of a disposal of subdivided shares under section CB 4
The rulings consider the treatment of a subdivision of shares and a disposal of subdivided shares (where the original shares were acquired for the purpose of disposal) under s CB 4 of the Income Tax Act 2007. The rulings conclude that:
• A subdivision of shares does not result in a disposal of personal property for the purposes of s CB 4;
• Section CB 4 will apply to a disposal of subdivided shares.
The central technical issue considered is whether subdivided shares are treated as the same or different property from the original shares. The conclusion is that they are the same.
The two rulings are contained in a single document with a shared commentary.
Ruling applies from: a 3 year period beginning on 21 May 2013 and ending on 20 May 2016
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BR Pub 13/01 - 13/02 - RTF format (315kb | 12 pages)
BR Pub 13/01 - 13/02 - PDF format (74kb | 12 pages)
Microsoft Word Viewer 2003 can be used to access .rtf (Rich Text Format) files.
Date published: 14 Apr 2010
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