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- Occasionally, a ruling is withdrawn before its expiry date. The table below indicates that a ruling has been withdrawn only if the ruling would be current if it had not been withdrawn.
Milldale Infrastructure LP
Applicant: Milldale Infrastructure LP
This product ruling concerns a funding arrangement that includes the advancement of an amount by Milldale Infrastructure LP (the Applicant) to the Developer for the Bulk Infrastructure required for a proposed housing development in Milldale (the Developer Loan); the satisfaction of the Developer’s obligation to repay part of the Developer Loan by registration of an encumbrance (the Final Encumbrance) over each subdivided section when title is issued; and the payment by future landowners of amounts (Infrastructure Payments) over the term of the Final Encumbrance.
Ruling applies from: 1 October 2018 to 30 June 2056
BR Prd 19/01 - PDF format (98kb | 5 pages)
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