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Share-based remuneration (including stock options) may on occasion be taken into account in the calculations underlying various service charges. We expect taxpayers to have kept the key underlying legal documentation and the detailed calculations confirming such expenditure. The facts and circumstances of these charges vary considerably, but will be closely examined if material.

There may also be considerable subjectivity in the calculation of share option costs (the Black-Scholes model, for example, relies on several major assumptions to arrive at a fair value). In the final analysis, we will check whether the overall charge is consistent with what an external party would pay for the service provided in the New Zealand market place. In particular, we do not accept notional sums being charged.

For larger New Zealand-based multinationals, consideration will be given regarding the charging of costs to offshore associates with staff that benefit from employee share/option schemes.