Tax Information Bulletin: Corrections
Corrected foreign currency amounts - conversion to New Zealand dollars
The exchange rates for the six months ending 30 September published in the October/November 2009 issue of the Tax Information Bulletin Vol 21, No 8, pp14-17, were incorrect. The correct tables and updated article are reproduced here.
Note: On 1 April 2009, Inland Revenue changed the method of sourcing such information and now uses wholesale rates from Bloomberg for rolling 12-month average, end of month and mid-month actual. These rates are now given in three tables. Previously the actual and average mid-month rates had been shown in one table.
This article provides the exchange rates acceptable to Inland Revenue for converting foreign currency amounts to New Zealand dollars under the controlled foreign company (CFC) and foreign investment fund (FIF) rules for the six months ending 30 September 2009. These exchange rates are found in the following tables.
You can choose either the:
- actual rate for the day for or each transaction (including closing market value), or
- average mid-month rate for the 12 months or the relevant period (see the table Currency rates 2009 - rolling 12-month average).
The Currency rates 2009 - end of month table, which provides the exchange rates on the last day of the month, is no longer necessary for the CFC or FIF rules but is provided to assist taxpayers who may need exchange rates on those days.
You must apply the chosen conversion method to all interests for which you use the FIF or CFC calculation method in that and each later income year.
To convert foreign currency amounts to New Zealand dollars for any country listed, divide the foreign currency amount by the exchange rate shown. Round the exchange rate calculations to four decimal places wherever possible. If you need an exchange rate for a country or a day not listed in the tables, please contact one of New Zealand’s major trading banks.
Currency rates 2009 - rolling 12-month average table
This table is the average of the mid-month exchange rate for that month and the previous 11 months, ie, the 12-month average.
Use this table to convert foreign currency amounts to New Zealand dollars for:
- FIF income or loss calculated under the accounting profits, comparative value, fair dividend rate, deemed rate of return, or cost methods under sections EX 49(8), EX 51, EX 57 and EX 56 of the Income Tax Act 2007
- branch equivalent income or loss calculated under the CFC and FIF rules pursuant to section EX 21(4) of the Income Tax Act 2007 for accounting periods of 12 months
- foreign tax credits calculated under the branch equivalent method for a CFC or FIF under section LJ 2 of the Income Tax Act 2007 for accounting periods of 12 months.
Currency rates 2009 - mid-month actual table
This table is the exchange rate on the 15th day of the month, or if no exchange rates were quoted on that day, on the preceding working day on which they were quoted. You can use the rate as the actual rate for any transactions arising on the 15th of the month.
Where the accounting period is less than or greater than 12 months, and branch-equivalent income or loss is calculated under the CFC or FIF rules pursuant to section EX21(4) of the Income Tax Act 2007, you can use the midmonth rate as the basis of the rolling average for the shorter or longer period (see Example 4).
Example 1A taxpayer with a 30 September balance date purchases shares in a Philippines company (which is a FIF but does produce a guaranteed yield) on 7 September 2009. Its opening market value on 1 October 2009 or its closing market value on 30 September 2009 is PHP 350,000. Using the comparative value method the opening market value is converted as follows: PHP 350,000 ÷ 34.3916 = $10,176.90 (In this example, the rate selected is the end-of-month rate for September 2009 for PHP.) |
Example 2A CFC resident in Hong Kong has an accounting period ending on 30 September 2009. Branch equivalent income for the period 1 October 2008 to 30 September 2009 is 200,000 Hong Kong dollars (HKD), which converts to: HKD 200,000 ÷ 4.5993 = $43,484.88 (In this example, the rate selected is the rolling 12-month average rate for September 2009 for HKD.) |
Example 3A resident individual with a 30 September 2009 accounting period acquires a FIF interest in a Japanese company in July 2009 for 10,500,000 yen. The interest is sold in September 2009 for 10,000,000 yen. Using the comparative value method, these amounts are converted as: JPY 10,500,000 ÷ 56.3883 = $186,208.84 JPY 10,000,000 ÷ 56.3883 = $177,341.75 (In this example, the rolling 12-month average rate for September 2009 has been applied to both calculations.) |
Example 4A CFC resident in Singapore was formed on 21 April 2009 and has a balance date of 30 September 2009. During the period 1 May 2009 to 30 September 2009, branch equivalent income of 500,000 Singaporean dollars was derived.
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Other pages in: Corrections
- Correction - to TIB Vol 24, No 3 (April 2012)
- Correction - to TIB Vol 23, No 9 (November 2011)
- Correction - to TIB Vol 23, No 3 (April 2011)
- Corrections - to TIB Vol 23, No 1 (February 2011)
- Summary of Supreme Court Ruling on "Trinity"
- Incorrect currency rates - October 2009
- Correction - incorrect figure in the National Average Market Values of Specified Livestock Determination, 2008
- Interim judgment printed in error
- Incorrect currency rates
- NZIT investments not exempt
- Correction
- Correction - SPS 07/05 - Transfer of depreciable property between associated persons - section EE 33 of the Income Tax Act 2004
- Correction - Operational Statement OS 06/01 GST Treatment of Supplies of Telecommunications Services
- Correction - SPS 06/02 Writing off outstanding tax
- Correction - to TIB Vol 19, No 3 (April 2007)
- Correction - FBT tax value of vehicle under different balance date scenarios
- Correction - Threshold to account for GST on a payments basis (May 2006)
Date published: 22 Feb 2010
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