CORPORATE TAXPAYERS GROUP
|
|
- Noah Brown
- 5 years ago
- Views:
Transcription
1 CORPORATE TAXPAYERS GROUP C/- Deloitte Attn: Mike Shaw P O Box 1990 WELLINGTON Telephone Facsimile Emissions Trading Scheme Tax Issues C/- Deputy Commissioner Policy Advice Division Inland Revenue Department PO Box 2198 WELLINGTON Dear Robin EMISSIONS TRADING TAX ISSUES The following submission has been prepared by the Corporate Taxpayers Group (the Group) on the Emissions Trading Tax Issues officials issues paper (the paper). This submission is concerned with the general tax issues that arise as a result of the proposed Emissions Trading Scheme (the Scheme) given they will likely have a material impact on New Zealand businesses. The Group will provide comments and suggestions on the design and administration of the Scheme to the relevant Select Committee once the Bill has been released. The Group s focus when making those comments will be to ensure that all aspects of the regime are appropriate, easily workable and result in low compliance costs, which is also the focus of this submission related to the tax aspects of the regime. Finally, this submission refers to New Zealand Units (NZUs), but all comments made in this submission are intended to apply equally to all international equivalents of NZUs as and to the extent to which these international equivalents are utilised under the New Zealand Scheme. SUMMARY The Group makes the following initial submission points and recommendations with respect to the paper. The Group s objective is that current tax principles apply to NZUs so as to not only ensure their tax treatment correlates with equivalent instruments but also to mitigate the need to legislate for separate regimes when minor additions to existing regimes may suffice. The Group is particularly looking for the tax treatment of NZUs to be as simple as possible to ensure that they do not result in high compliance costs to taxpayers.
2 Page 2 of 8 The general tax principles that should guide the taxation treatment of NZUs include the capital revenue boundary i.e. units allocated for capital items should not be taxable, whereas units allocated for revenue items should be taxable. Further, that any market value fluctuations should be deferred from a tax perspective until those gains have been realised. The Inland Revenue should specifically clarify the application of key provisions and regimes to NZUs, for example the interplay with the financial arrangement rules and whether, say, NZUs will be specifically included as an excepted financial arrangement. The Inland Revenue also needs to be ready to respond quickly to any tax issues that may arise from NZU related transactions that are not currently envisaged (given the emerging nature of NZUs and the developing manner in which market forces will respond to this business issue). The Group expects that such issues may arise as derivatives are developed to help businesses manage their obligations under this regime. Free units The Group believes that the tax treatment of the free allocation of units should remain flexible and should be based on normal tax principles. As the free NZUs are in effect compensation to the taxpayer, the treatment of the allocation should be determined with reference to the nature of compensation being provided. If the free NZU is allocated specifically to compensate increased revenue costs (for example, electricity) to the taxpayer then the NZU should be treated as revenue and taxable. If the free NZU is allocated to compensate the taxpayer for say a diminution of the value of the taxpayer s business / capital asset / structure (as a result of the implementation of the Scheme) then the free allocation should be classified as capital (including the subsequent gains or losses on the disposal of the free units). The Group notes that the paper is written on the assumption that the issue of free NZUs is for increased revenue costs. This will not be the case in all circumstances and as far as many taxpayers are concerned, the free units partially compensate them for a reduction in the value of their business / capital asset / structure. Where both capital and revenue components are present, appropriate apportionment methodologies should be available to taxpayers and accepted by the Inland Revenue. In terms of free NZUs that are issued to offset a direct NZU obligation of the taxpayer (i.e. the taxpayer has a liability of 1 NZU and therefore receives 1 free NZU), the result should always be a nil tax effect impact for that taxpayer. Specifically income and deemed deductions for the free NZU should be valued at nil to produce a nil result, or alternatively the free NZU should be treated as income at the same value and time as the obligation to surrender NZUs, again producing a nil result. In terms of free NZUs that are taxable, the NZUs should be taxable on an accrual basis and taxpayers should have flexibility on when they return this income, that is, the free NZU should be deemed to be derived based on an emerging basis that reflects their business. The Group believes that the method taxpayers adopt for financial reporting purposes should also be legislated as acceptable for tax purposes. The value attributed to free NZUs that are taxable should be viewed as derived under the taxpayers emerging basis and should not be the market value at year end. Rather it should be the market value at the time when the NZUs are issued to the taxpayer (i.e. the opening market value) or the market value at the time when the NZUs are treated as being derived (i.e. throughout the income year, namely an average market value).
3 Page 3 of 8 Given this, there is no need to separately value such free NZUs held at year end for tax purposes as there should be no mark to market type calculation done each year in relation to NZUs. Acquired NZUs to meet NZU obligations (i.e. which will be on revenue account) Such NZUs acquired by taxpayers during a year should be deductible when incurred. At year end, NZU s acquired by taxpayers that are not attributable to that years carbon obligations should be added back for tax purposes in accordance with EA 3 principles and deducted in the following year. Losses made on excess NZUs acquired during the year and still held at year end should be able to be taken into account in the year, equivalent to valuing trading stock on a lower of cost or market methodology. Accruals of NZU obligations (which will be on revenue account) At year end taxpayers that have not acquired sufficient NZUs to meet their obligations for that year can accrue for tax purposes an amount of estimated expenditure expected to be incurred to purchase NZUs to meet their obligations. The Group believes that the method taxpayers adopt for financial reporting purposes should also be legislated as acceptable for tax purposes. Deductibility of emission activities The Group considers that the standard tax deductibility analysis should provide for deductions for costs associated with emissions obligations, including any costs associated with the trading of NZU and any other charges imposed on emitters under the Scheme; however the Group is supportive of the introduction of a specific deductibility provision so as to ensure that there is absolute clarity on this point. Alternatively, the deductibility position should be clearly articulated in a Tax Information Bulletin. Other For GST purposes the supply of NZUs should be zero rated to reduce complexity when NZUs are traded. The Group believes that penalties imposed under the Scheme (as originally proposed) should be deductible where the taxpayer has unintentionally calculated their obligation incorrectly as the penalty has no regard to culpability there is no public policy grounds to negate a deduction being taken akin to other normal business expenditure. The Group does not provide any comment on the taxation of NZUs as they relate to forestry. DETAILED COMMENTS The Group provides detailed comments on general tax issues in Appendix One.
4 Page 4 of 8 CONCLUSION The Group thanks you for the opportunity to comment on the paper. For your information, the members of the Corporate Taxpayers Group are: 1. Air New Zealand Limited 2. AMP Life Limited 3. ANZ National Bank Limited 4. ASB Bank Limited 5. AXA New Zealand Limited 6. Bank of New Zealand 7. Contact Energy Limited 8. Fletcher Building Limited 9. Fonterra Cooperative Group Limited 10. General Electric 11. Goodman Fielder New Zealand Limited 12. The Hongkong and Shanghai Banking Corporation Limited (New Zealand branch) 13. IAG New Zealand Limited 14. Infratil Limited 15. Lion Nathan Limited 16. New Zealand Funds Management Limited 17. New Zealand Post Limited 18. New Zealand Exchange Limited 19. Rio Tinto Alcan (New Zealand) Limited 20. Shell New Zealand Limited 21. SKYCITY Entertainment Group Limited 22. Sky Network Television Limited 23. Telecom New Zealand Limited 24. Telstra Clear Limited 25. TOWER Limited 26. Toll New Zealand Limited 27. Turners and Growers Limited 28. Vector Limited 29. Vodafone New Zealand Limited 30. Westpac New Zealand Limited 31. ZESPRI International Limited We note that the views in this document are a reflection of the views of the Corporate Taxpayers Group and do not necessarily reflect the view of individual members. Yours sincerely John Payne For the Corporate Taxpayers Group
5 Page 5 of 8 APPENDIX ONE GENERAL TAX ISSUES Free allocation of NZUs The Group believes that the tax treatment of the free allocation of units should remain flexible and should be based on normal tax principles. As the free NZUs are in effect compensation to the taxpayer, the treatment of the allocation should be determined with reference to the nature of compensation being provided. If the free NZU is allocated specifically to compensate increased revenue costs (for example, electricity) to the taxpayer then the NZU should be treated as revenue. If the free NZU is allocated to compensate the taxpayer for say a diminution of the value of the taxpayer s business / capital asset / structure (as a result of the implementation of the Scheme) then the free allocation should be classified as capital (including the subsequent gains or losses on the disposal of the free units). The Group notes that the paper is written on the assumption that the issue of free NZUs is for increased revenue costs. This will not be the case in all circumstances and as far as many taxpayers are concerned, the free units partially compensate them for a reduction in the value of their business / capital asset / structure. To provide certainty to taxpayers the Group recommends that a provision be inserted into the Act to clarify when the receipt of free NZUs is income to the taxpayer. If the free allocation of NZUs is explicitly provided to taxpayers in relation to capital expenditure (e.g. for building new plant), this receipt should not be taxable income. It is an affair of capital and should not be taxed. To immediately tax these units will result in the taxpayer having an inappropriate timing disadvantage. In that case the value of the free NZUs should be offset against the depreciable base of the capital asset. Gains or losses on the subsequent sale of these units should also be outside the tax base. The following comments deal with situations where the free units are within the tax base, which is the assumption upon which the paper is drafted. By making these comments the Group does not wish to detract from the general view of many taxpayers that the free units partially compensate them for a reduction in the value of their business / capital asset / structure, and as such are an affair of capital. In terms of free NZUs that are issued to offset a direct NZU obligation of the taxpayer (i.e. the taxpayer has a liability of 1 NZU and therefore receives 1 free NZU), the result should always be a nil tax effect impact for that taxpayer. Specifically income and deemed deductions for the free NZU should be valued at nil to produce a nil result, or alternatively the free NZU should be treated as income at the same value and time as the obligation to surrender NZUs, again producing a nil result. Timing The free allocation of the NZUs should be taxable on an accrual basis and taxpayers should have flexibility on when they return this income, that is, the free NZU should be deemed to be derived based on an emerging basis that reflects their business. The Group believes that the method taxpayers adopt for financial reporting purposes should also be legislated as acceptable for tax purposes.
6 Page 6 of 8 The value attributed to free NZUs which have been derived under the taxpayers emerging basis, should not be the market value at year end, rather it should be the market value at the time when the NZUs are issued to the taxpayer (i.e. the opening market value) or the market value at the time when the NZUs are treated as being derived (i.e. throughout the income year, namely an average market value). The Group believes that taxpayers should have certainty with respect to the income from holding NZUs hence our submission that they should not be valued at year end market value. Noting that if the derived free NZUs are required to be valued at the year end market value, this will give rise to material fluctuations in income tax liabilities which could inappropriately expose such taxpayers to use of money interest. Adopting this approach there is no need to separately value free NZUs held at year end for tax purposes as there should be no mark to market type calculation done each year in relation to NZUs. Free NZUs sold during the year should result in the full net gain or loss (not already recognised) to be recognised in the year of sale. A reason for the above treatment is that the Group believes that taxpayers should return income and pay provisional tax with some certainty; unexpected gains/losses from disposing of NZUs should be deferred until when those NZUs are sold. At the extreme, the proposed Scheme operates with all taxpayers having to settle obligations on 31 March for the calendar year; on that date the market price of NZUs could have a price spike. It would be totally inappropriate for March balance date taxpayers to use such a price to value excess NZUs on hand. Acquired NZUs to meet NZU obligations (i.e. which will be on revenue account) NZUs acquired by taxpayers during a year should be deductible when incurred. At year end, NZUs acquired by taxpayers that are not attributable to that years carbon obligations should be added back for tax purposes in accordance with section EA 3 principles and deducted in the following year. In relation to excess NZUs acquired during the year (i.e. those NZUs that will not in any way be used for that year) the Group also recommends that to the extent that such NZUs have reduced in value during the period that this reduction in value can be deducted during the period. This is the equivalent of valuing such NZUs at the lower of cost or market value. The Group acknowledges officials position that excepted financial arrangements are only able to be valued at cost, not the lower of cost or market value. Clearly other forms of trading stock can be valued at the lower of cost or market value. The Group believes that this is the correct approach for valuing excess NZUs (i.e. acquired NZU in excess of the taxpayer s obligations at year end). This is because: If taxpayers are forced to value at the cost, should the price reduce below its cost, taxpayers will be forced to sell excess NZUs prior to year end to obtain the tax deduction (otherwise they will only have a deferred tax asset). While taxpayers may make these commercial decisions, we are concerned that the Inland Revenue may argue that this amounts to tax avoidance; we see no economic benefit in having any regime that provides this uncertainty. For accounting purposes, the Group understands that taxpayers will value at the lower of cost or market with the proviso that they can opt to value at fair value (if there is an active market). That is, many taxpayers will simply value at the lower of cost or market and they should not be forced to apply different tax treatment as this only raises compliance costs.
7 Page 7 of 8 The rationale for valuing excepted financial arrangements (i.e. shares) at cost was to limit the ability for taxpayers to defer recognition of gains (by valuing shares that have increased in value at cost), but recognise unrealised losses (by valuing shares that have lost value at market value). We understand officials were most concerned with situations where such taxpayers had overall net gains in equity holdings but, given the ability to claim unrealised losses, had net tax losses. To prevent taxpayers only market valuing losses, all shares that are held on revenue account now have to be valued at cost. We believe that this rationale should not apply to NZUs as the purpose of purchasing NZUs is to meet emissions obligations over the short term rather than to speculate on the change in NZUs value over time. Tax deductibility The Group believes that the standard tax deductibility provisions in the Income Tax Act should be sufficient to provide deductions for expenditure incurred by taxpayers relating to emission obligations, including any costs associated with the trading of NZU and any other charges imposed on emitters under the Scheme. However, to provide certainty to taxpayers the Group believes that the insertion of a deductibility provision in the Act would put the matter beyond doubt for taxpayers. An alternative would be to outline the tax deductibility of costs associated with meeting emissions obligation in a Tax Information Bulletin. The Group also believes that penalties imposed under the Scheme should be deductible to taxpayers when the taxpayer did not intentionally fail to meet their obligations under the Scheme. For example, if a taxpayer accidentally underestimated their obligation they would potentially be penalised under the Scheme at a fixed price per tonne of carbon shortfall. Generally penalties are not deductible under public policy grounds when the activity resulting in the penalty is considered too remote from the income earning process and the taxpayer should not receive favourable treatment when they have done a wrongful act (e.g. traffic fines). However, in relation to the Scheme many of the penalties appear to be for calculation and interpretation issues (e.g. different interpretation for measurement of emissions); such penalties should be tax deductible. This is especially relevant given the science and technology involved in measuring emissions is new to both taxpayers and the Inland Revenue, and can be subjective. Further the nature of the current proposed penalties mean that penalties under the Scheme are virtually inevitable from time to time reinforcing that public policy should not apply to deny a deduction for the penalty imposed under the Scheme. Accrual of NZU obligations At year end taxpayers that have not acquired sufficient NZUs to meet their obligations for that year can accrue for tax purposes an amount of estimated expenditure expected to be incurred to purchase NZUs to meet their obligations. The Group believes that the method taxpayers adopt for financial reporting purposes should also be legislated as acceptable for tax purposes. The Group therefore supports officials view that deductions should be available as the taxpayer incurs obligations under the Scheme. That is, taxpayers should be able to accrue a liability for cost of acquiring NZUs to satisfy their obligations for emitting greenhouse gases. This treatment is consistent with general principles.
8 Page 8 of 8 GST To ensure simplicity when NZUs are traded the Group recommends that a supply of NZUs should be zero rated. The Group does not support having GST charged at 12.5% on the transfer of NZUs. The concern the Group has with the transfer of NZUs at 12.5% GST is that it will add considerable complexity and uncertainty when taxpayers acquire (and sell) NZUs, especially should the NZUs trade on a market. Specifically, before anyone will know what price to pay for a NZU they will need to know: 1. Whether the price of the NZUs quoted is GST inclusive or exclusive (including whether the vendor is resident or not) 2. Whether appropriate tax invoices will be issued, and when they will be issued. That is, subject to understanding exactly how the regime will operate, the GST implications could materially impact on the efficiency and effectiveness of the market. For example, a taxpayer would not want to pay $ (being $100 plus GST of $12.50) for an NZU until they were absolutely sure that they could recover the $12.50 as GST input tax. The above also raises a number of system changes that would need to be incorporated into a market trading system. Overlaying the above, we can not see any tax policy rationale why NZUs should have GST charged at 12.5%. Specifically, we suspect all (New Zealand) taxpayers that will be acquiring NZUs to meet obligations under the Scheme will be GST registered and the acquisition of the NZUs will be in the course of furtherance of a taxable activity. That is they will recover all GST input tax charged. Where taxpayers are simply trading in NZUs, there should be no GST cost from trading in them. That is, if GST is to be charged at 12.5%, then they should be able to recover all GST input tax and pay GST output tax on the sale of the NZUs. We see no economic or tax policy gain from having such taxpayers account for GST, rather we see material implications for the smooth running of an efficient and effective market (as discussed above). Consistent with this proposed treatment the Group notes that there is no underlying supply of a good or service. While it is stated in the paper that a NZU is a chose in action, the Group considers that it is more akin to a penalty (for emitting) or a proxy for a tax. Imposing GST on top of the price of the NZU would be effectively imposing a tax on a tax.
Corporate Taxpayers Group
#004 Corporate Taxpayers Group c / - R e b e c c a O s b o r n l D e l o i t t e l P O B o x 1 9 9 0 l W e l l i n g t o n l + 6 4 ( 0 ) 4 4 7 0 3 6 9 1 C T G Treaty Related Measures to Prevent BEPS C-/
More informationKPMG Centre 18 Viaduct Harbour Avenue P.O. Box 1584 Auckland New Zealand
KPMG Centre 18 Viaduct Harbour Avenue P.O. Box 1584 Auckland New Zealand Telephone +64 (9) 367 5800 Fax +64 (9) 367 5875 Internet www.kpmg.com/nz GST - Current issues Deputy Commissioner, Policy and Strategy
More informationGST on low value imported goods: an offshore supplier registration system. CA ANZ Submission, June 2018
GST on low value imported goods: an offshore supplier registration system CA ANZ Submission, June 2018 2 Contents Cover letter... 4 General comments... 7 Offshore supplier registration: scope of the rules...10
More informationA simpler option is to extend the inter-company dividend exemption
KPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand Telephone +64 (4) 816 4500 Fax +64 (4) 816 4600 Internet www.kpmg.com/nz Deputy Commissioner Policy and Strategy Inland Revenue Department PO
More informationTaxation (GST and Remedial Matters) Bill
Taxation (GST and Remedial Matters) Bill Officials Report to the Finance and Expenditure Committee on s on the Bill October 2010 Prepared by the Policy Advice Division of Inland Revenue and the Treasury
More informationC o r p o r a t e T a x p a y e r s G r o u p
C o r p o r a t e T a x p a y e r s G r o u p c / - R e b e c c a O s b o r n l D e l o i t t e l P O B o x 1 9 9 0 l W e l l i n g t o n l + 6 4 ( 0 ) 4 4 7 0 3 6 9 1 C T G Clerk of the Committee Finance
More informationSAMPLE SUPERANNUATION FUND STATEMENT OF FINANCIAL POSITION AS AT 30 JUNE 2009
STATEMENT OF FINANCIAL POSITION AS AT 30 JUNE 2008 $ $ Investments Shares in Listed Companies (Australian) 356,412.00 239,866.00 $356,412.00 $239,866.00 Other Assets Cash at Bank 96,556.10 129,211.78 Income
More informationCHAPTER 6 - HOW SUPERANNUATION AND LIFE INSURANCE SAVINGS ARE TO BE TAXED
87 CHAPTER 6 - HOW SUPERANNUATION AND LIFE INSURANCE SAVINGS ARE TO BE TAXED 6.1 Introduction For the reasons given in Chapter 5, the preferential tax treatment of superannuation cannot be justified on
More informationPolicy concerns implementation should be deferred
KPMG Centre 18 Viaduct Harbour Ave PO Box 1584 Auckland 1140 New Zealand T: +64 9 367 5800 Our ref: 180516KPMGsubRingFencing Ring-fencing rental losses C/- Deputy Commissioner, Policy and Strategy Inland
More informationIN THE COURT OF APPEAL OF NEW ZEALAND CA253/04
IN THE COURT OF APPEAL OF NEW ZEALAND CA253/04 BETWEEN AND JEFFREY GEORGE LOPAS AND LORRAINE ELIZABETH MCHERRON Appellants THE COMMISSIONER OF INLAND REVENUE Respondent Hearing: 16 November 2005 Court:
More informationTax Working Group Information Release. Release Document. September taxworkingroup.govt.nz/key-documents
Tax Working Group Information Release Release Document September 2018 taxworkingroup.govt.nz/key-documents This paper contains advice that has been prepared by the Tax Working Group Secretariat for consideration
More informationGuidelines On the Income Tax Treatment From Adopting FRS 139 Financial Instruments: Recognition And Measurement
Guidelines On the Income Tax Treatment From Adopting FRS 139 Financial Instruments: Recognition And Measurement (Applicable To Financial Institution Only) 1 1. INTRODUCTION 1.1 The objective of these Guidelines
More informationPEPANZ Submission: New Zealand Emissions Trading Scheme Review 2015/16
29 April 2016 NZ ETS Review Consultation Ministry for the Environment PO Box 10362 Wellington 6143 nzetsreview@mfe.govt.nz PEPANZ Submission: New Zealand Emissions Trading Scheme Review 2015/16 Introduction
More informationNew Zealand s International Tax Review
New Zealand s International Tax Review Extending the active income exemption to non-portfolio FIFs An officials issues paper March 2010 Prepared by the Policy Advice Division of Inland Revenue and the
More informationKPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand
KPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand Telephone +64 (4) 816 4500 Fax +64 (4) 816 4600 Internet www.kpmg.com/nz C/- Deputy Commissioner Policy and Strategy Inland Revenue Department
More informationBlack hole and feasibility expenditure a Government discussion document. 6 July 2017
Black hole and feasibility expenditure a Government discussion document 6 July 2017 6 July 2017 Black hole and feasibility expenditure proposals C/- Deputy Commissioner, Policy and Strategy Inland Revenue
More informationReview of the thin capitalisation rules
15 February 2013 Review of the Thin Capitalisation Rules Deputy Commissioner, Policy and Strategy Policy Advice Division Inland Revenue Department PO Box 2198 Wellington 6140 By email: policy.webmaster@ird.govt.nz
More informationRegulatory Impact Statement
Regulatory Impact Statement GST: change in use adjustments, supply of accommodation, transactions involving nominations, and application of section 19D to non-profit bodies Agency Disclosure Statement
More informationTopics for NZ ETS Review 2015/2016 consultation
Topics for NZ ETS Review 2015/2016 consultation About the consultation The Government is reviewing the New Zealand Emissions Trading Scheme (NZ ETS) to assess how it should evolve to support New Zealand
More informationGST: Accounting for land and other high-value assets
GST: Accounting for land and other high-value assets A government discussion document Hon Peter Dunne Minister of Revenue First published in November 2009 by the Policy Advice Division of Inland Revenue,
More informationSERVICES-RELATED PAYMENTS:
SERVICES-RELATED PAYMENTS: RESTRICTIVE COVENANTS AND EXIT INDUCEMENTS Contents Introduction...1 Submissions... 2 Restrictive covenant payments...3 Problem... 3 Proposed solution... 4 Exit inducement payments...5
More informationAUSTRALIA S CARBON POLLUTION REDUCTION SCHEME
AUSTRALIA S CARBON POLLUTION REDUCTION SCHEME AUSTRALIA S CARBON POLLUTION REDUCTION SCHEME Presentation to the Eighth Annual Workshop on Greenhouse Gas Emission Trading Howard Bamsey Deputy Secretary
More informationFinancial information
Financial information 135 Significant forecasting assumptions and risks Greater Wellington Draft Long-Term Plan 2012-22 These prospective financial statements were authorised for issue by the Council on
More informationTAX IMPLICATIONS RELATED TO THE IMPLEMENTATION OF FRS 139: FINANCIAL INSTRUMENTS: RECOGNITION & MEASUREMENT (FOR NON-FINANCIAL INSTITUTIONS)
The Malaysian Institute of Certified Public Accountants DISCUSSION PAPER TAX IMPLICATIONS RELATED TO THE IMPLEMENTATION OF FRS 139: FINANCIAL INSTRUMENTS: RECOGNITION & MEASUREMENT (FOR NON-FINANCIAL INSTITUTIONS)
More informationKPMG submission - ED0184: Filing an IR 10 and section 108 of the TAA 1994
KPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand Telephone +64 (4) 816 4500 Fax +64 (4) 816 4600 Internet www.kpmg.com/nz Team Manager Technical Services Office of the Chief Tax Counsel Inland
More informationTAXATION (ANNUAL RATES AND REMEDIAL MATTERS) BILL
TAXATION (ANNUAL RATES AND REMEDIAL MATTERS) BILL Commentary on the Bill Hon Bill English Minister of Finance Minister of Revenue First published in May 1999 by the Policy Advice Division of the Inland
More informationBlack hole R&D expenditure
Black hole R&D expenditure A government discussion document Hon Steven Joyce Minister of Science and Innovation Hon Todd McClay Minister of Revenue First published in November 2013 by Policy and Strategy,
More informationKPMG submission: Bright-line test for sales of residential property Issues Paper
KPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand Telephone +64 (4) 816 4500 Fax +64 (4) 816 4600 Internet www.kpmg.com/nz Deputy Commissioner Policy and Strategy Inland Revenue PO Box 2198
More informationINTEREST ON USE OF MONEY RECENT DETERMINATIONS MADE BY THE COMMISSIONER PROVISIONAL TAX RECALCULATIONS FIRE LOSSES - SECTION 108 INCOME TAX ACT 1976
RECENT DETERMINATIONS MADE BY THE COMMISSIONER Six determinations were issued by the Commissioner on the 4th of December 1989. Below is a short explanation of each. The full determinations are printed
More informationChapter 7 Answers. [0001] Question 1. Solution
Chapter 7 Answers [0001] Question 1 (a) Spreading Methods The available spreading methods are (s EW 14): International Financial Reporting Standards (IFRS) financial reporting method (ss EW 15B to EW 15I);
More information2 December Gavin Quigan Manager, Superannuation Schemes Compliance Monitoring Financial Markets Authority PO Box 1179 Wellington 6140
MCA NZ Limited PO Box 8811 Symonds Street Auckland 1150 SuperLife House 41 Charlotte St Eden Terrace 1021 T (09) 375 9800 F (09) 375 9801 E mca@mcanz.co.nz 2 December 2011 Gavin Quigan Manager, Superannuation
More informationAPPENDIX 4E STATEMENT
A.B.N. 99 080 135 913 APPENDIX 4E STATEMENT Preliminary Final Report For the year ended 30 June 2013 (Previous corresponding period is year ended 30 June 2012) CONTENTS Results for announcement to the
More informationNZ TOP 10 FUND FINANCIAL STATEMENTS FOR THE PERIOD 9 SEPTEMBER 2016 TO 31 MARCH 2017
FINANCIAL STATEMENTS FOR THE PERIOD 9 SEPTEMBER 2016 TO 31 MARCH 2017 BEING THE FIRST FINANCIAL STATEMENTS FOR THE NZ TOP 10 FUND FOLLOWING THE RESETTLEMENT OF THE NZX10 FUND AS THE NZ TOP 10 FUND ON 7
More informationNZ CASH FUND FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 MARCH Presented by Smartshares Limited, Manager of the NZ Cash Fund
FINANCIAL STATEMENTS Presented by Smartshares Limited, Manager of the NZ Cash Fund TABLE OF CONTENTS Page Directory 1 Statement by the Manager 2 Financial Statements Statement of Comprehensive Income 3
More informationNEW ZEALAND BOND TRUST
FINANCIAL STATEMENTS Presented by Smartshares Limited, Manager of the New Zealand Bond Trust TABLE OF CONTENTS Page Directory 1 Statement by the Manager 2 Financial Statements Statement of Comprehensive
More informationTax implications of certain asset transfers
Tax implications of certain asset transfers In-kind distributions and gifts Transfers of assets on a taxpayer s death An officials issues paper April 2003 Prepared by the Policy Advice Division of the
More informationB.14 (Climate Change) Vote Environment. Report in relation to selected Non-Departmental Appropriation for the year ended 30 June 2015
B.14 (Climate Change) Vote Environment Report in relation to selected Non-Departmental Appropriation for the year ended 30 June 2015 Presented to the House of Representatives pursuant to the Public Finance
More informationTaxation (Bright-line Test for Residential Land) Bill
Taxation (Bright-line Test for Residential Land) Bill Officials Report to the Finance and Expenditure Committee on s on the Bill October 2015 Prepared by Policy and Strategy, Inland Revenue CONTENTS Bright-line
More informationCompany Number: IMPERIAL BRANDS FINANCE PLC. Annual Report and Financial Statements 2017
Company Number: 03214426 IMPERIAL BRANDS FINANCE PLC Annual Report and Financial Statements 2017 Board of Directors J M Jones N J Keveth (resigned 31 March 2017) D I Resnekov O R Tant M A Wall (appointed
More information18 August 2017 The National Treasury 240 Madiba Street PRETORIA 0001
18 August 2017 The National Treasury 240 Madiba Street PRETORIA 0001 The South African Revenue Service Lehae La SARS, 299 Bronkhorst Street PRETORIA 0181 BY EMAIL: Nombasa Langeni (Nombasa.Langeni@treasury.gov.za)
More informationDraft Question We ve Been Asked PUB00296: When is income from a cash dividend paid on ordinary shares derived?
Draft Question We ve Been Asked PUB00296: When is income from a cash dividend paid on ordinary shares derived? 22 December 2017 22 December 2017 Team Manager, Technical Services Office of the Chief Tax
More informationLambton Quay, Wellington 6011, PO Box 1214, Wellington 6140, New Zealand Phone: Fax:
www.lgnz.co.nz 114 118 Lambton Quay, Wellington 6011, PO Box 1214, Wellington 6140, New Zealand Phone: 64 4 924 1200 Fax: 64 4 924 1230 Submission to the Ministry for the Environment In the matter of Updating
More informationSydney Desalination Plant Pty Limited Financial Statements for the year ended 30 June 2011
Sydney Desalination Plant Pty Limited Financial Statements for the year ended 30 June 2011 Sydney Desalination Plant Pty Limited - 30 June 2011 Page 1 Contents Directors Report Page 3 Auditor s Independence
More informationCASINO CONTROL ACT AMEND- MENTS TO THE GOODS AND SERVICES TAX ACT 1985
CASINO CONTROL ACT 1990 - AMEND- MENTS TO THE GOODS AND SERVICES TAX ACT 1985 SUMMARY This item explains the amendments contained in the Casino Control Act 1990 which amend the Goods and Services Tax Act
More informationFinancial Statements 2017
Financial Statements 2017 The Insurance & Financial Services Ombudsman Scheme Inc. is independent, impartial and free for consumers. We resolve complaints about insurance & financial services. Contact
More informationTaxing securities lending transactions: substance over form
Taxing securities lending transactions: substance over form A government discussion document Hon Dr Michael Cullen Minister of Finance Minister of Revenue First published in November 2004 by the Policy
More informationTaxation (Annual Rates, Business Taxation, KiwiSaver, and Remedial Matters) Bill
Taxation (Annual Rates, Business Taxation, KiwiSaver, and Remedial Matters) Bill Officials Report to the Finance and Expenditure Committee on s on the Bill Volume 3 Research and development Penalties Company
More informationGST: A Review. A Government discussion document
GST: A Review A Government discussion document GST: A review. A tax policy discussion document. First published in March 1999 by the Policy Advice Division of the Inland Revenue Department, PO Box 2198,
More informationThe accounting income method (AIM) for paying provisional tax
The accounting income method (AIM) for paying provisional tax As part of legislation enacted on 21 February 2017, the Taxation (Business Tax, Exchange of Information, and Remedial Matters) Act 2017, a
More informationAnnual Report June 2005
40 Annual Report June 2005 Sky Network Television Limited and subsidiary FINANCIAL INFORMATION Sky Network Television Limited and subsidiary Financial Trends Statements 42 Directors Responsibility Statement
More informationFinancial Statements 2018
Financial Statements 2018 The Insurance & Financial Services Ombudsman Scheme Inc. is independent, impartial and free for consumers. We resolve complaints about insurance & financial services. Contact
More informationAPN Asian REIT Fund. Annual Report for the Financial Year Ended 30 June 2017 ARSN APN ASIAN REIT FUND ANNUAL REPORT
APN Asian REIT Fund ARSN 162 658 200 Annual Report for the Financial Year Ended 30 June 2017 APN ASIAN REIT FUND ANNUAL REPORT 2017 1 Directors report The directors of APN Funds Management Limited (ACN
More informationHerd scheme elections
Herd scheme elections An officials issues paper August 2011 Prepared by the Policy Advice Division of Inland Revenue and the New Zealand Treasury First published in August 2011 by the Policy Advice Division
More informationSUBMISSION ON THE ADDRESSING HYBRID MISMATCH ARRANGEMENTS GOVERNMENT DISCUSSION DOCUMENT
#012 11 November 2016 Addressing hybrid mismatch arrangements C/- Deputy Commissioner Policy and Strategy Inland Revenue Department POBox2198 Wellington 6140 ASB Barh L n \lt.xi PO Box 35, Shor tland Street
More informationRESEARCH PAPER EMISSIONS TRADING SCHEMES
IASB MEETING - Week beginning 17 May 2010 AGENDA PAPER 10A RESEARCH PAPER EMISSIONS TRADING SCHEMES [XXX 2010] Author: Nikolaus Starbatty Correspondence directed to: Allison McManus amcmanus@iasb.org 1
More informationSubmission on proposed IPP and compliance reporting
Transpower House, 96 The Terrace, PO Box 1021, Wellington, New Zealand Telephone +64-4-590 7000 Facsimile: +64-4-495 7100 www.transpower.co.nz Jeremy.cain@transpower.co.nz 04 590 7544 11 July 2014 Brett
More informationTaxation (Land Information and Offshore Persons Information) Bill
Taxation (Land Information and Offshore Persons Information) Bill Officials Report to the Finance and Expenditure Committee on s on the Bill July 2015 Prepared by Policy and Strategy of Inland Revenue
More informationAustralia and New Zealand Banking Group Limited New Zealand Branch Disclosure Statement
Australia and New Zealand Banking Group Limited New Zealand Branch Disclosure Statement FOR THE YEAR ENDED 30 SEPTEMBER 2011 NUMBER 11 ISSUED NOVEMBER 2011 Australia and New Zealand Banking Group Limited
More informationKPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand
KPMG 10 Customhouse Quay P.O. Box 996 Wellington New Zealand Telephone +64 (4) 816 4500 Fax +64 (4) 816 4600 Internet www.kpmg.com/nz Deputy Commissioner Policy and Strategy Division Inland Revenue P O
More informationProperty Council Feedback on the Tax Working Group s (TWG) Interim Report
1 November 2018 Tax Working Group Email: submissions@taxworkinggroup.govt.nz Dear Tax Working Group members, Property Council Feedback on the Tax Working Group s (TWG) Interim Report 1. Executive Summary
More informationGST - MEANING OF PAYMENT
GST - MEANING OF PAYMENT This item clarifies what is a payment for the purposes of section 20(3)(a)(ia) of the Goods and Services Tax Act 1985. Subsection (2) of section 6 of the Goods and Services Tax
More informationBSP CONVERTIBLE NOTES LIMITED FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2011
BSP CONVERTIBLE NOTES LIMITED FINANCIAL STATEMENTS BSP CONVERTIBLE NOTES LIMITED FINANCIAL STATEMENTS CONTENTS PAGE NO. Table of Contents 1 DIRECTORS REPORT 2 INDEPENDENT AUDITORS REPORT 5 STATEMENT OF
More informationRecognition of Deferred Tax Assets for Unrealised losses (Amendments to NZ IAS 12)
Recognition of Deferred Tax Assets for Unrealised losses (Amendments to NZ IAS 12) This Standard was issued on 31 March 2016 by the New Zealand Accounting Standards Board of the External Reporting Board
More informationBeing a Participant in the Emissions Trading Scheme. User Guide
Being a Participant in the Emissions Trading Scheme User Guide 2 About this user guide This guide will give you general information about being a Participant in the Emissions Trading Scheme (ETS). Intended
More informationNotes Statkraft AS Group
STATKRAFT AS GROUP FINANCIAL STATEMENTS Notes Statkraft AS Group Index of notes to the consolidated financial statements General Note 1 Note 2 Note 3 Note 4 Note 5 General information and summary of significant
More informationFinancial Statements of the Government of New Zealand
Financial Statements of the Government of New Zealand For the Eight Months Ended 28 February 2006 7 April 2006 Prepared by The Treasury Printed by PrintLink ISBN 0-478-18291-0 This document is available
More informationThe Society had previously noted with concern the impact of the new regime on business that is already in force.
12 February 2008 Taxation of Life Insurance c/- Deputy Commissioner, Policy Policy Advice Division Inland Revenue Department PO Box 2198 WELLINGTON Dear Sir REVIEW OF LIFE INSURANCE TAXATION This submission
More informationHarding Loevner Emerging Markets Equity Fund ARSN Financial Statements for the reporting period ended 30 June 2016
Harding Loevner Emerging Markets Equity Fund ARSN 604 215 296 Financial Statements for the reporting period ended 30 June 2016 Harding Loevner Emerging Markets Equity Fund ARSN 604 215 296 Financial Statements
More informationNZ BOND FUND FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 MARCH Presented by Smartshares Limited, Manager of the NZ Bond Fund
FINANCIAL STATEMENTS Presented by Smartshares Limited, Manager of the NZ Bond Fund TABLE OF CONTENTS Page Directory 1 Statement by the Manager 2 Financial Statements Statement of Comprehensive Income 3
More informationTHE TRUST COMPANY DIVERSIFIED PROPERTY FUND. Annual Financial Report for the reporting period ended 30 June 2014 ARSN
THE TRUST COMPANY DIVERSIFIED PROPERTY FUND Annual Financial Report for the reporting period ended 30 June 2014 ARSN 155 454 078 THE TRUST COMPANY DIVERSIFIED PROPERTY FUND ARSN 155 454 078 ANNUAL FINANCIAL
More informationSSAP 12 STATEMENT OF STANDARD ACCOUNTING PRACTICE 12 INCOME TAXES
SSAP 12 STATEMENT OF STANDARD ACCOUNTING PRACTICE 12 INCOME TAXES (Issued August 2002) Contents Paragraphs OBJECTIVE SCOPE 1-4 DEFINITIONS 5-11 Tax Base 7-11 RECOGNITION OF CURRENT TAX LIABILITIES AND
More informationStrategic Fixed Interest Trust. Annual Report - 30 June Contents ARSN
Strategic Fixed Interest Trust Annual Report - 30 June 2009 ARSN 116 735 703 Contents 2 Directors report 5 Auditor s independence declaration 6 Income statement 7 Balance sheet 8 Statement of change in
More informationRing-fencing rental losses
Ring-fencing rental losses An officials issues paper March 2018 Prepared by Policy and Strategy, Inland Revenue, and the Treasury First published in March 2018 by Policy and Strategy, Inland Revenue, PO
More informationInternational Financial reporting standards. March 2006
International Financial reporting standards March 2006 International financial reporting standards The group has disclosed the impact of adopting New Zealand standards which comply with International Financial
More informationThis Regulatory Impact Statement has been prepared by the Ministry for the Environment.
Regulatory Impact Statement: Carbon Price Methodology for the Synthetic Greenhouse Gas Levy Regulatory Impact Statement Carbon Price Methodology for the Synthetic Greenhouse Gas Levy Agency Disclosure
More informationASIA PACIFIC FUND FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 MARCH Presented by Smartshares Limited, Manager of the Asia Pacific Fund
FINANCIAL STATEMENTS Presented by Smartshares Limited, Manager of the Asia Pacific Fund TABLE OF CONTENTS Page Directory Statement by the Manager 2 Financial Statements Statement of Comprehensive Income
More informationTAX INFORMATION BULLETIN NO.11 J U N E CONTENTS. Time-Share Apartments - Profits on sale subject to tax...2. Livestock Farming Regime...
TAX INFORMATION BULLETIN NO.11 J U N E 1 9 9 0 CONTENTS Time-Share Apartments - Profits on sale subject to tax...2 Livestock Farming Regime...3 In Specie Distributions...3 Accident Compensation Levies
More informationChanges to the GST rules
23 December 2010 A special report from the Policy Advice Division of Inland Revenue Changes to the GST rules This special report provides early information about the main changes to the GST rules relating
More informationFor personal use only
Aberdeen Actively Hedged International Equities Fund ARSN 088 905 033 Annual financial report Aberdeen Actively Hedged International Equities Fund ARSN 088 905 033 Annual financial report Contents Page
More informationBARRAMUNDI LIMITED FINANCIAL STATEMENTS CONTENTS FOR THE YEAR ENDED 30 JUNE Page. Statement of Comprehensive Income 1
FINANCIAL STATEMENTS CONTENTS Page Statement of Comprehensive Income 1 Statement of Changes in Equity 2 Statement of Financial Position 3 Statement of Cash Flows 4 Notes to the Financial Statements 5 STATEMENT
More informationTaxation (Annual Rates, GST and Miscellaneous Provisions) Bill
Taxation (Annual Rates, GST and Miscellaneous Provisions) Bill Commentary on the Bill Hon Dr Michael Cullen Minister of Finance Minister of Revenue First published in May 2000 by the Policy Advice Division
More informationRecognition of Deferred Tax Assets for Unrealised Losses Amendments to Ind AS 12, Income Taxes
Exposure Draft Recognition of Deferred Tax Assets for Unrealised Losses Amendments to Ind AS 12, Income Taxes (Last date for the comments: 20 th February, 2017) Issued by Accounting Standards Board The
More information24 November 2016 The National Treasury 240 Vermeulen Street PRETORIA 0001
24 November 2016 The National Treasury 240 Vermeulen Street PRETORIA 0001 The South African Revenue Service Lehae La SARS, 299 Bronkhorst Street PRETORIA 0181 BY EMAIL: Mmule Majola (mmule.majola@treasury.gov.za)
More informationIncome Taxes- Ind AS 12
Income Taxes- Ind AS 12 Agenda 1. Scope and key terms 2. Recognition and Measurement principles 3. Consolidation Outside tax basis 4. Uncertain tax positions 5. Presentation and Disclosures 6. Summary-Nine
More informationSTUDENTS TRUST INTERNATIONAL PLANS Canadian $ Students Trust International Plan
STUDENTS TRUST INTERNATIONAL PLANS Canadian $ Students Trust International Plan Financial Statements as of and for the year ended September 30, 2015 and Independent Auditors Report TABLE OF CONTENTS Page
More informationFINANCIAL REPORT. Commonwealth Investment Funds. Year ended 30 June 2015
FINANCIAL REPORT Commonwealth Investment Funds Year ended 30 June 2015 COMMONWEALTH INVESTMENT FUNDS FINANCIAL REPORT Responsible Entity of the Funds COLONIAL FIRST STATE INVESTMENTS LIMITED ABN: 98 002
More informationGST ROLE OF SECTION 5(14) OF THE GOODS AND SERVICES TAX ACT 1985 IN REGARD TO THE ZERO-RATING OF PART OF A SUPPLY
Interpretation Statement: IS 08/01 GST ROLE OF SECTION 5(14) OF THE GOODS AND SERVICES TAX ACT 1985 IN REGARD TO THE ZERO-RATING OF PART OF A SUPPLY Summary 1. All legislative references are to the Goods
More informationTAXREP 22/14 (ICAEW REPRESENTATION 56/14)
TAXREP 22/14 (ICAEW REPRESENTATION 56/14) ICAEW TAX REPRESENTATION REVIEW OF EXISTING VAT LEGISLATION ON PUBLIC BODIES AND TAX EXEMPTIONS IN THE PUBLIC INTEREST ICAEW welcomes the opportunity to comment
More informationStandard Life Investments Global Corporate Bond Trust ARSN Annual report For the year ended 30 June 2017
Standard Life Investments Global Corporate Bond Trust ARSN 125 896 184 Annual report For the year ended 2017 Standard Life Investments Global Corporate Bond Trust ARSN 125 896 184 Annual report For the
More informationTax Alert. June A focus on topical tax issues June 2014 In this issue. GST - Timing errors do matter
Tax Alert A focus on topical tax issues In this issue GST - Timing errors do matter Overseas borrowings on offshore rental property a new focus Questions Inland Revenue has been asked on tax avoidance
More informationIFP Global Franchise Fund (Hedged) ARSN Annual report - 30 June 2015
ARSN 138 878 092 Annual report - 30 June ARSN 138 878 092 Annual report - 30 June Contents Page Directors' Report 1 Auditor's Independence Declaration 4 Statement of Comprehensive Income 5 Statement of
More informationAUSTRALIAN PROPERTY FUND
FINANCIAL STATEMENTS Presented by Smartshares Limited, Manager of the Australian Property Fund TABLE OF CONTENTS Page Directory 1 Statement by the Manager 2 Financial Statements Statement of Comprehensive
More informationFinancial Report Retail Mortgage
Financial Report Retail Mortgage FOR THE FINANCIAL YEAR ENDED 30 JUNE 2014 BOOKLET 11 i Financial Reports for the financial year ended June 2014. The schemes listed in Booklet 11 are noted below. Statements
More informationAUSTRALIAN TOP 20 FUND
FINANCIAL STATEMENTS FOR THE SIX MONTHS ENDED 30 SEPTEMBER Presented by Smartshares Limited, Manager of the Australian Top 20 Fund TABLE OF CONTENTS Page Directory 1 Statement by the Manager 2 Financial
More informationNorthern Ireland Electricity (The NIE Transmission, Distribution and Landbank Businesses) 31 March Summary Regulatory Accounts
Northern Ireland Electricity (The NIE Transmission, Distribution and Landbank Businesses) Summary Regulatory Accounts Summary Regulatory Accounts CONTENTS Statement of Directors Responsibilities 2 Auditors
More informationExposure Draft ED/2009/2 Income Tax
Deloitte Touche Tohmatsu 2 New Street Square London EC4A 3BZ United Kingdom Tel: +44 (0)20 7936 3000 Fax: +44 (0)20 7583 8517 www.deloitte.com Sir David Tweedie Chairman International Accounting Standards
More informationMEETING THE OBLIGATIONS TO FILE RETURNS AND PAY TAX ON TIME
MEETING THE OBLIGATIONS TO FILE RETURNS AND PAY TAX ON TIME DRAFT LEGISLATION AND COMMENTARY Memorandum submitted on 3 March 2010 by the Tax Faculty of the Institute of Chartered Accountants in England
More informationBUNNINGS LIMITED ANNUAL REPORT FOR THE YEAR ENDED 30 JUNE Page 1. Contents. 2. Annual Report. 3. Corporate Information
ANNUAL REPORT Page 1. Contents 2. Annual Report 3. Corporate Information 4. Statement of Comprehensive Income 5-6. Statement of Financial Position 7. Statement of Changes in Equity 8. Statement of Cash
More informationFINANCIAL STATEMENTS
FINANCIAL STATEMENTS CONTENT Income statements 38 Balance sheets 39 Statements of recognised income and expense 40 Cash flow statements 41 Notes to the financial statements* Consolidated Parent 1 Summary
More informationFidelity Capital Guaranteed Bond Limited. Interim Report for the six months ended 31 December 2010
Interim Report for the six months ended Contents Page(s) Directors' responsibility statement 1 Chairman's report 1 Condensed statement of comprehensive income 2 Condensed balance sheet 2 Condensed statement
More information