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Inland Revenue

Tax Policy

GST record-keeping requirements


(Corporate Taxpayers Group, New Zealand Institute of Chartered Accountants, PricewaterhouseCoopers)

  1. The proposed amendment is supported. (Corporate Taxpayers Group, New Zealand Institute of Chartered Accountants, PricewaterhouseCoopers)
  2. The amendment should be accompanied by commentary that clarifies:
    • The Commissioner’s position on what “reasonable conditions” may be imposed. (Corporate Taxpayers Group)
    • What constitutes “reasonable notice” for withdrawing of an authorisation to keep records offshore. (New Zealand Institute of Chartered Accountants)
  3. The GST registration form for non-residents should incorporate an option to apply for approval to store records offshore. (PricewaterhouseCoopers)
  4. The legislation should state that Guidelines released by the Commissioner should contain terms that are no more stringent than would be expected from a New Zealand-based server, except where those terms are needed to combat identified flight risks. (New Zealand Institute of Chartered Accountants)


The first three submissions all raise points related to the administration and implementation of the proposed rule. Policy officials will pass the submissions onto the relevant units within Inland Revenue for their consideration.

Officials consider that the NZICA submission on guidelines not being stricter than that expected of New Zealand-based server is a matter for the guidelines themselves, rather than being set down in legislation. The proposed GST rule is designed to mirror a provision that applies to income tax records, which was recently inserted into the Tax Administration Act 1994. To avoid confusion, it is important to keep the two provisions consistent to the greatest extent possible. That way, when guidance is provided for one provision, it should be equally applicable to the other.


That the NZICA submission on legislation imposing conditions on the guidelines should be declined, and that all other submissions be noted.