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Inland Revenue

Tax Policy

PUBLISHED 29 August 2000

Trans-Tasman "triangular taxation" to be examined

The Australian and New Zealand governments are to examine the tax treatment of trans-Tasman investment, Australian Treasurer Peter Costello and New Zealand Treasurer Michael Cullen announced today. That examination will include consideration of the issue of "triangular" imputation credits. See media statement.

Hon Dr Michael Cullen


Hon Peter Costello
Treasurer, Australia

Hon Dr Michael Cullen
Treasurer, Finance and Revenue Minister, New Zealand

Australia and New Zealand to examine Trans Tasman tax issues - Costello/Cullen

Australia and New Zealand are to examine the tax treatment of Trans Tasman investments, the Australian Treasurer Peter Costello and New Zealand Treasurer Michael Cullen announced today.

Consideration will be given to the issue of "triangular taxation".

This occurs where Australian shareholders in a New Zealand company operating in Australia are unable to access Australian sourced franking credits, with the same problem applying in reverse for New Zealand shareholders in Australian companies operating in New Zealand.

Both Treasurers agree that the examination of triangular taxation is a worthwhile step in addressing possible barriers to trans Tasman investment. In Australia the Ralph Review of Business Taxation recommended an examination of triangular taxation.

Ministers have instructed officials in both countries to develop a workable model for recognition of imputation credits in triangular cases, and assess the costs and benefits of applying such a model. Officials are expected to report back on the issue by 30 June 2001.

Business will be consulted during the development of the model. In Australia this consultation will form part of the business tax reform process, and in New Zealand it will form part of the normal generic tax policy process.

It is expected that our announcement of the examination of the triangular issue will be reflected in the communiqu' that issues from our Trade Ministers' meeting in Auckland on 30-31 August 2000 to discuss ways of expanding and deepening Closer Economic Relations cooperation.

Contact: David Carrigan [tax policy adviser, Dr Cullen's office] 471-9728