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Technical tax area
Te wahi mo te take hangarau
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. If you have any inquiries about public rulings, please contact our Technical Services team.

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


Income tax - Standard project agreement for a public-private partnership

These two public rulings, BR Pub 13/05 to BR Pub 13/06, deal with certain aspects of the income tax treatment of the standard form contract for public-private partnerships prepared by the Treasury. These two rulings do not consider the tax implications of any funding agreements or other contracts entered into by the parties.

The two rulings are contained in a single document with a shared commentary.

Ruling applies from: an indefinite period beginning on 21 October 2013.

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BR Pub 13/05 - 13/06 - RTF format (528kb | 35 pages)
BR Pub 13/05 - 13/06 - PDF format (165kb | 35 pages)


Income tax - treatment of unclaimed amounts of $100 or less

The rulings consider the income tax treatment of amounts of unclaimed money of $100 or less. BR Pub 13/03 considers when unclaimed amounts not held on trust will be business income of the holder, and BR Pub 13/04 provides that unclaimed amounts held on trust will not be business income of the holder.

The two rulings are contained in a single document with a shared commentary.

Ruling applies from: the period beginning on the first day of the 2013/14 income year to the last day of the 2016/17 income year.

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BR Pub 13/03 - 13/04 - RTF format (463kb  | 22 pages )
BR Pub 13/03 - 13/04 - PDF format (134kb  | 22 pages)


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)


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Other rulings by year

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

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Date published: 14 Apr 2010

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