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Technical tax area
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Technical tax area: Public rulings

Download 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.

Public rulings are issued by the Office of the Chief Tax Counsel (OCTC) business group of Inland Revenue. Please contact us if you have any inquiries about public rulings.

All the public rulings issued to date for the current year are displayed here by year, number (BR Pub), title, and status.


BR Pub 15/11: Fringe benefit tax - exclusion for car parks provided on an employer’s premises and BR Pub 15/12: Fringe benefit tax - exclusion for car parks provided on the premises of a company that is part of the same group of companies as an employer

These public rulings address the on-premises exclusion from FBT for car parking provided to employees in car parks that are owned or leased by an employer. BR Pub 15/11 sets out that car parks provided by an employer to an employee will be exempt from FBT where the car park is on premises that the employer owns or leases. BR Pub 15/12 sets out the rule for group companies.

We have prepared an operational position explaining the process for employers who consider they may have overpaid FBT. You can find this in the "Operational positions" section in the left menu.

Ruling applies from: This ruling will apply for an indefinite period beginning on 17 November 2015.

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BR Pub 15/11 and BR Pub 15/12 - PDF format (372kb | 35 pages)


BR Pub 15/10: Goods and services tax - directors' fees

This Ruling and Commentary explains whether a director’s fees are subject to GST. Essentially, if a registered person accepts an office as a director in carrying on a taxable activity, the fees that person receives for providing their services will be subject to GST.

Ruling applies from: This ruling will apply for an indefinite period beginning on 30 June 2014.

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BR Pub 15/10 - PDF format (211kb | 19 pages)


BR Pub 15/04 - BR Pub 15/09: Income tax - interest deductibility - Roberts and Smith - borrowing to replace and repay amounts invested in a business or other income-earning activity

The six public rulings consider the deductibility of interest in certain situations where a partnership or taxpayer borrows funds which are used to replace and repay existing funding. The existing funding must have been used in the business or other income earning activity, and have been deductible. The public rulings are re-issues of existing rulings that expire on 24 May 2015.

Ruling applies from: These rulings will apply for an indefinite period beginning on 24 May 2015.

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BR Pub 15/04 to BR Pub 15/09 - PDF format (331kb | 40 pages)


BR Pub 15/03: Goods and Services Tax - legal services provided to non-residents relating to transactions involving land in New Zealand

The public ruling is a reissue of the ruling that applies to the supply by a registered person of legal services to a non-resident (who is outside New Zealand at the time the services are performed) relating to:

  • transactions involving the sale or purchase of land in New Zealand or the lease, licence, or mortgage of land in New Zealand, or
  • easements, management agreements, construction agreements, trust deeds, guarantees and other agreements concerning land in New Zealand, or
  • disputes arising in relation to land in New Zealand.

These supplies will be zero-rated for GST purposes under s 11A(1)(k) of the Goods and Services Tax Act 1985.

Ruling applies from: This Ruling will apply for an indefinite period beginning on 24 May 2015.

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BR PUB 15/03 - PDF format (277Kb | 14 pages)


BR Pub 15/01 and BR Pub 15/02: secondhand goods input tax deductions - fishing quota, coastal permits and certificates of compliance

These rulings consider whether a registered person is entitled to claim secondhand goods input tax deductions when they purchase fishing quota, coastal permits or certificates of compliance from an un-registered person. The rulings conclude that they are not "goods" as defined in the Goods and Services Tax Act 1985. Therefore, they will not give rise to secondhand goods input tax deductions

Ruling applies from: This Ruling will apply for an indefinite period beginning on 1 July 2014.

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BR PUB 15/01 and BR PUB 15/02 - PDF format (272kb | 15 pages)


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Other rulings by year

|  All public rulings  | 2015  | 2014  | 2013  | 2012  | 2010  | 2009  | 2008  | 2007  | 2006  | 2005  | 2004  | 2003  | 2002  | 2001  | 2000  | 1999  | 1998  | 

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