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Technical tax area
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Technical tax area: Product rulings

Download product rulings

We issue product rulings only if both the following conditions are met:

  • it is not feasible to seek a private ruling on the arrangement (this is generally because the identities of the other parties may not be known), and
  • the characteristics of the taxpayers who may enter into the arrangement do not affect the content of the ruling.

Product rulings are issued by the Office of the Chief Tax Counsel (OCTC) business group of Inland Revenue. Please contact us if you have any inquiries about product rulings.

The table below lists product rulings issued by year and number (BR Prd), with a brief description of the subject matter (earlier years will progressively be added).

Caution should be exercised when considering these product rulings:

  • Product rulings apply only to the arrangement specified in the ruling. A general similarity to an arrangement will not necessarily lead to the same tax result.
  • Rulings generally expire after three years.
  • The table below does not indicate whether a ruling has expired (the expiry date of a ruling is set out in the text under the heading "The period for which this Ruling applies").
  • Occasionally, a ruling is withdrawn before its expiry date. The table below indicates that a ruling has been withdrawn only if the ruling would be current if it had not been withdrawn.

PGG Wrightson Limited

Applicant: PGG Wrightson Limited
This ruling applies to the return of excess capital in PGG Wrightson Limited to its shareholders by way of an off-market, pro rata repurchase and cancellation of PGG Wrightson Limited shares, following the sale of PGG Wrightson Seeds Holdings Limited.

Ruling applies from: 30 October 2018 to 31 October 2021

BR Prd 18/05 - PDF format (109kb | 2 pages)

Livestock Improvement Corporation Limited

Applicant: Applicant: Livestock Improvement Corporation Limited
This ruling covers the reclassification of two classes of shares (Co-operative Control Shares and Investment Shares) into a single, continuing class of shares (Ordinary Shares) listed on the New Zealand Alternative Market Exchange (NZAX).

Ruling applies from: 9 February 2018 to 31 March 2019

BR Prd 18/01 - PDF format (121 kb | 6 pages)

Bank of New Zealand (BNZ)

Applicant: Bank of New Zealand (BNZ)
This ruling applies to a BNZ product called TotalMoney, a package of accounts and loans offered to customers. TotalMoney allows customers to group or aggregate accounts for the purposes of either “pooling” or “offsetting” the account balances.

Ruling applies from: 1 April 2018 to 31 March 2022

BR Prd 18/03 - PDF format (172kb | 8 pages)

Harbour Fund III GP Limited

Applicant: Harbour Fund III GP Limited
The Arrangement is the receipt by the Harbour Fund III Limited Partnership of proceeds pursuant to individual funding agreements that the Fund will enter into with litigation claimants to a proposed class action against Carter Holt Harvey Limited and the other Carter Holt Harvey entities, under which the Fund will agree to pay all legal and other costs incurred by the Claimants, in return for a share of the Proceeds.

Ruling applies from: 15 February 2018 to 15 February 2021

BR Prd 18/02 - PDF format (116kb | 8 pages)

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Other rulings by year

2018 | 2017 | 2016 | 2015 | 2014 | 2013 | 2012 | 2011 | 2010 | 2009 | 2008 | 2007 | 2006 | 2005 | 2004 | 

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