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Inland Revenue

Tax Policy

PUBLISHED 6 September 2016

Hybrids discussion document released

The Government has released a discussion document containing proposals for addressing hybrid mismatch arrangements. The discussion document proposes that New Zealand adopts the OECD recommendations on hybrid mismatch arrangements and calls for submissions on how that could best be done. For more information see the media statement and the discussion document. Submissions close on 17 October 2016 [extended to 11 November 2016].

Hon Michael Woodhouse
Minister of Revenue

6 September 2016

BEPS proposals released for consultation

A strategy used by some large multinationals to shift profits overseas and minimise their New Zealand tax is the focus of international tax proposals released for consultation today, says Revenue Minister Michael Woodhouse.

“A discussion document which proposes that New Zealand adopt the OECD recommendations on hybrid mismatch arrangements was today released for consultation,” says Mr Woodhouse.

“Our international tax rules are sound, but the Government considers that New Zealand’s rules on hybrids can be stronger.

“Hybrid mismatch arrangements are one of the base erosion and profit shifting strategies used by multinationals to exploit the difference between how two countries might treat a cross-border transaction, resulting in less tax.”

The OECD recommendations remove the advantage of using hybrids.

“It is important that our rules complement those of other countries, particularly Australia and the UK who have both announced their intentions to adopt the OECD recommendations in this area.”

Submissions on the proposals close on 17 October 2016. The discussion document is available at