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Technical tax area
Ngā tūmomo whakataunga me ngā aratohu

Company amalgamation

These items clarify some specific company amalgamation tax issues.


QB 14/05: Income tax - ASC rules: Calculating the "subscriptions" amount for an amalgamated company when the shares of an amalgamated company are held by another amalgamated company

This QWBA addresses a question relating to the calculation of the Available Subscribed Capital (ASC) of an amalgamated company following an amalgamation. The question arose following the release of a QWBA on a related issue (also concerning the calculation of ASC after an amalgamation). This QWBA is released to clarify an additional point that was not addressed in the previous QWBA. The QWBA concludes that the ASC of an amalgamated company does not include the ASC of amalgamating companies that are subsidiaries of other amalgamating companies.

QB 14/05 - PDF format (77kb | 5 pages)

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QB 13/02: Income tax - determining the "subscriptions" amount for an amalgamated company under the available subscribed capital rules

This QWBA clarifies the effect of section CD 43(15)(a)(iii) of the Income Tax Act 2007. The item concludes that section CD 43(15)(a)(iii) operates to prevent the double-counting of an amalgamated company's "subscriptions".

QB 13/02 - PDF format (25kb | 3 pages)

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QB 14/05: Income tax - ASC rules: Calculating the "subscriptions" amount for an amalgamated company when the shares of an amalgamated company are held by another amalgamated company

This QWBA addresses a question relating to the calculation of the Available Subscribed Capital (ASC) of an amalgamated company following an amalgamation. The question arose following the release of a QWBA on a related issue (also concerning the calculation of ASC after an amalgamation). This QWBA is released to clarify an additional point that was not addressed in the previous QWBA. The QWBA concludes that the ASC of an amalgamated company does not include the ASC of amalgamating companies that are subsidiaries of other amalgamating companies.

QB 13/02: Income tax - determining the "subscriptions" amount for an amalgamated company under the available subscribed capital rules

This QWBA clarifies the effect of section CD 43(15)(a)(iii) of the Income Tax Act 2007. The item concludes that section CD 43(15)(a)(iii) operates to prevent the double-counting of an amalgamated company's "subscriptions".

The impact of company amalgamations on financial arrangement determinations

This item clarifies whether the rights and obligations arising to an amalgamating taxpayer under a financial arrangement determination will pass to the amalgamated company on the amalgamation.