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Delays to response times: It is taking longer than usual to answer calls and myIR messages, and to process some COVID-19 Support Payment applications. This is because of the impact of COVID-19. If possible, please contact us through your myIR account. Log in to myIR

Budget 2022: The Government has announced Budget 2022, which includes changes to child support payments. Find out more on our Tax Policy website

Budget 2022: The Government has announced a Cost of Living Payment, which will be paid from 1 August 2022. You do not need to apply for this payment. If you are eligible, we’ll pay it into your bank account. Find out more

The tax affairs of people currently stranded in New Zealand may also be affected by double tax agreements (DTAs). When there is double taxation, a DTA will generally apply. The residence tests in DTAs are interpreted in a holistic and integrated manner and it is not expected that persons will be treated as resident under DTAs just because of the current emergency conditions.

Recently, the OECD has published guidance concerning international tax treaty rules and the response to the COVID-19 emergency. The OECD considers that a company’s place of effective management will not change because of the displacement of senior executives. The OECD does not consider that the current emergency will change how a PE is determined. This is because temporary changes of location under emergency conditions should not create new PEs for the employer. Also, if contracts are concluded temporarily at employees’ or agents’ homes under the current emergency then there is no PE created for the businesses involved. The OECD considers that the COVID-19 emergency is unlikely to change residency status under a tax treaty.

In Australia, the ATO has also published their position on these matters which is very much in line with the above guidance.

Competent authority assistance is available if treaty partners are taking different positions to those taken by Inland Revenue and we would encourage early engagement if any difficulties are experienced

OECD Secretariat Analysis of Tax Treaties and the Impact of the COVID-19 Crisis

Last updated: 28 Apr 2021
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