Trans-Tasman "triangular tax": discussion document released

The Australian and New Zealand governments today released a discussion document outlining proposals to relieve the double taxation of investments in Australian and New Zealand companies that operate in both countries. As a solution to the "triangular tax" problem, the discussion document proposes widening each country's imputation laws to include companies resident in the other country, allocating both imputation and franking credits to shareholders in proportion to their ownership of a company. For more information see today's media release from Australian Treasurer Peter Costello and New Zealand Finance and Revenue Minister Michael Cullen. The discussion document "Trans-Tasman triangular tax" is published here.

Hon Dr Michael Cullen
Minister of Finance

JOINT MEDIA STATEMENT

Oz-NZ governments to consult on triangular tax

The Australian and New Zealand governments are consulting with taxpayers in both countries about possible changes to deal with concerns relating to the taxation of certain trans-Tasman investments.

Proposed changes are set out in a discussion document, "Trans-Tasman triangular tax", released today by Australian Treasurer Peter Costello and New Zealand Finance and Revenue Minister Michael Cullen.

Triangular taxation 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.

"We are pleased to be examining this issue, which business in both countries has long highlighted as a barrier to trans-Tasman investment flows," Mr Costello and Dr Cullen said today. "The release of this discussion document is a further example of the commitment of both governments to the CER relationship and the facilitation of trans-Tasman business."

"Clearly, triangular tax reform requires a bilateral approach that preserves the Australian and New Zealand tax bases and is acceptable to business and government in both countries."

"The mechanism under consideration is one that allocates both Australian franking credits and New Zealand imputation credits to shareholders in proportion to their ownership of a company."

"We are inviting the views of businesses, the tax community and other interested parties on the workability of the proposed changes. Their responses will contribute to the decision of whether or not to proceed with the proposals," Mr Costello and Dr Cullen said.

The discussion document is available in electronic format at www.treasury.gov.au and www.taxpolicy.ird.govt.nz.

Submissions, which close on 3 May 2002, should be addressed to either:

Assistant Commissioner
Law, Design and Development
(Entities and Imputation)
Tax Design Group
Australian Taxation Office
PO Box 900
Civic Square ACT 2608
CANBERRA

The General Manager
Policy Advice Division
Trans-Tasman Triangular Tax
Inland Revenue Department
PO Box 2198
WELLINGTON

Or email:
Australia: [email protected]
New Zealand: [email protected]

Contact: Patricia Herbert [senior press secretary] 471-9412, 021-270-9013, [email protected]. Technical inquiries to David Carrigan, IRD, 04-474-7146 or 021-432-100