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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.


Extension of Public Ruling BR Pub 08/03: Projects to reduce emissions programme - Income tax treatment

BR Pub 08/03 considered the income tax consequences of certain agreements entered into between the Crown and participants for the provision of emission units in exchange for the implementation of projects which would reduce carbon emissions. These agreements expired on 31 December 2013. However, this ruling also considers sales of emission units by participants to third parties, which may still occur. As this arrangement has a limited nature , and a limited number of participants, the Commissioner has decided not to re-issue this ruling and instead, extend BR Pub 08/03 under section 91DD of the Tax Administration Act 1994.

Ruling applies from: 1 January 2014 until 31 December 2018.


BR PUB 08/03 - RTF format (40kb | 1 page)
BR PUB 08/03 - PDF format (63kb | 1 page)


BR Pub 14/08: Income Tax - Timing of disposal and derivation of income from trading stock

The ruling considers when income arises from trading stock. Sections CB 1 and CB 2 provide that income either arises when it is derived (when a legally enforceable debt or the right to be paid arises) or when the parties intend property in the stock to pass. If there is no clear intention, the Sale of Goods Act 1908 decides when property passes.

Ruling applies from: the first day of the 2014/15 income year.


BR PUB 14/08 - RTF format (289kb | 14 pages)
BR PUB 14/08 - PDF format (288kb | 14 pages)


BR Pub 14/07: Deductibility - Interest repayments required as a result of the early repayment of a financial arrangement

The ruling considers the income tax consequences when a person requires early repayment of their term deposit, either in part or in full. In particular, the ruling considers the application of the financial arrangements rules and deduction rules where the interest rate applied to the withdrawn amount is lowered, and the person is required to repay some of the interest already received back to the lender.

Ruling applies from: 17 December 2013.


BR PUB 14/07 - RTF format (334kb | 22 pages)
BR PUB 14/07 - PDF format (287kb | 22 pages)


BR Pub 14/06: Payments made by parents or guardians of students to state schools - GST treatment

This re-issued public ruling addresses the GST treatment of payments made by the parents or guardians of students (other than international students) who are enrolled at state and integrated schools to the Boards of Trustees of such schools. The ruling does not reflect any material change in the Commissioner’s position on the GST treatment of payments made by parents to state and integrated schools. However, aspects of the ruling have been updated with assistance from the Ministry of Education to reflect their advice to school communities in revised Education circular 2013/06 - Payments by parents of students in state and state-integrated schools issued on 13 June 2013.

Ruling applies from: the period 21 June 2013 to 20 June 2018.

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BR PUB 14/06 - RTF format (284kb | 19 pages)
BR PUB 14/06 - PDF format (247kb | 19 pages)


Income tax - Australian source income earned by Australian limited partnership and foreign tax credits

These five reissued rulings deal with the ability of a New Zealand resident partner of an Australian limited partnership to claim foreign tax credits for Australian income tax and dividend withholding tax paid by the Australian limited partnership. The rulings are contained in a single document with a shared commentary.

Ruling applies from: 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 14/01 - 14/05 - RTF format (466kb | 31 pages)
BR PUB 14/01 - 14/05 - PDF format (231kb | 31 pages)


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Other rulings by year

|  All public rulings  | 2014  | 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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