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Inland Revenue

Tax Policy

Consultation
Last updated 4 December 2025
Closing date 5 February 2026

Status Current

Consultation on taxation of company loans to shareholders

Inland Revenue has launched public consultation on proposals to improve the way new loans by companies to shareholders are taxed.

The main proposal is for a new time limit rule that would treat certain shareholder loans as dividends if not repaid within 12 months from the end of the income year they were made. This proposal would only apply to new loans, not existing ones, and only when a company’s total lending to shareholders is $50,000 or more. 

For more information see:

  • officials' issues paper and information sheet linked below
  • media release