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Technical tax area
Ngā tūmomo whakataunga me ngā aratohu
Technical tax area: Public rulings

Download public rulings

Inland Revenue issues public rulings to interpret how a tax law applies to taxpayers and specific types of arrangements. Taxpayers whose circumstances match those in a ruling may apply it, but are not obliged to do so.

If you calculate your tax liability according to an applicable public binding ruling, we must assess your tax according to that ruling. A public ruling applies only to the particular taxation law and arrangement set out in the ruling, and only for a specified period. If there is any material difference between the facts in the ruling and your actual arrangement, the ruling does not apply.

Public 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 public rulings.

All the public rulings issued to date for the current year are displayed here by year, number (BR Pub), title, and status.


BR Pub 18/06: Goods and services tax - payments made by parents to state and state integrated schools

GST is not chargeable on payments made by parents to the board of trustees of a state or state integrated school where the payments are made to assist the school with the cost of delivering education services which the student has a statutory entitlement to receive free of charge. GST is chargeable on payments made for supplies of other goods or services that are not integral to the supply of education to which the student has a statutory entitlement, where that supply is conditional on the payment being made. This Ruling is a reissue of BR Pub 14/06 which expired on 20 June 2018. It is substantially the same as BR Pub 14/06 but some parts have been rewritten to improve readability, and legislative changes have been included. A new example (Example 5) has been added. The Ruling refers to Circular 2018/01 Payments by parents of students in schools (Ministry of Education, 2018).

Ruling applies from: This ruling will apply for the period beginning 21 June 2018 and ending on 20 June 2023.


BR Pub 18/06 - PDF format (343kb | 22 pages)


BR Pub 18/01-BR Pub 18/05: Income tax - Australian limited partnership and foreign tax credits

These five Public Rulings deal with the ability of a NZ resident partner of an Australian limited partnership to claim foreign tax credits for Australian income tax and dividend withholding tax paid by an Australian limited partnership. They are a reissue of BR Pub 14/01 to 14/05. The Rulings discuss Australian limited partnerships that are corporate limited partnerships for Australian tax purposes and are treated under Australian tax law as companies while in NZ retaining partnership and flow through tax treatment. The Rulings conclude that a foreign tax credit will be available to the NZ partners of an Australian limited partnership for Australian income tax or dividend withholding tax that is paid by the limited partnership in certain situations. While the conclusions do not differ from those reached in BR Pub 14/01 to 14/05, the reissued rulings contain a number of minor changes to reflect amendments to legislation.

Ruling applies from: These rulings will apply from the first day of the 2017/18 income year to the last day of the 2021/22 income year.


BR Pub 18/01 - BR Pub 18/05 - PDF format (466kb | 33 pages)


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Other rulings by year

|  All public rulings  | 2018  | 2017  | 2016  | 2015  | 2014  | 2013  | 2012  | 2010  | 2009  | 2008  | 2007  | 2006  | 2005  | 2004  | 2003  | 2002  | 2001  | 2000  | 1999  | 1998  | 

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