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Inland Revenue

Tax Policy

Government tax policy work programme 2016-17 - as at 16 August 2017

As at 16 August 2017 (see the page history for details of changes).

A summary of the Government’s tax policy work programme, as announced by the Minister of Revenue in March 2015 and updated in November 2016.

For more information see Inland Revenue's 2016 regulatory management document and 2017 regulatory stewardship stratgey; and the Minister of Revenue's speech to the CA ANZ conference on 17 November 2016.

The tax policy work programme covers these areas:

Enhancements to tax policy within broad-base, low-rate (BBLR) tax settings
Review of the tax framework for employee share schemes Reforming the tax treatment of employee share schemes to ensure appropriate and balanced outcomes.
Income protection insurance: a review The Financial Services Council is seeking a review of the income tax treatment of income protection insurance. There is a lack of clarity about the tax treatment of this form of insurance and inconsistencies across products offering similar benefits.
Deductibility of holding costs for revenue account property Considering the deductibility of holding costs for property.
Abusive tax position penalty Examining the application of the abusive tax position penalty in cases of tax avoidance, and whether any changes are needed to the penalty.
Demergers Considering an exclusion from dividend taxation for corporate demergers.
Petroleum mining decommissioning expenditure Replacing the existing ability to spread back petroleum mining decommissioning expenditure to earlier tax years with a refundable tax credit in the current year.
Review of bank account requirement for offshore persons’ IRD numbers The bank account requirement for an offshore person to obtain an IRD number continues to cause issues in practice. In particular, it is an obstacle in a number of cases to people being able to comply with their tax obligations.
Trust beneficiaries as settlors There are instances when beneficiaries of trusts who leave their beneficiary income in the current accounts with the trust become inadvertent settlors. This is not in accordance with the policy intent.
Financial arrangement issues There are a variety of financial arrangement taxation issues ranging from remedial to policy enhancements to ensure these rules work as intended.
Taxation of non-bank securitisation vehicles Extending the current securitisation regime to beyond banks.
Impact of case law on the ”voting interest” test for corporate trustees Considering the impact of recent case law on the application of the voting interest test in the Income Tax Act 2007 and the Goods and Services Tax Act 1985 to corporate trustees.
Repeal adverse events income equalisation deposit regime This regime is, in practice, little used, because the main scheme offers more flexibility. However, its existence can cause some confusion.
Review of donee status applications Dealing with applications by organisations for donee status under schedule 32.
Treaty of Waitangi settlements Tax implications of Treaty settlements are addressed as required.
Feasibility and black hole expenditure (new) Reviewing the rules on deductions for the costs related to undertaking feasibility studies and other possible black hole expenditures.
GST on imported low-value goods (new) Working with the New Zealand Customs Service to support the development of a regime to collect GST on low value imported goods.
Employee share schemes – deferral regime for start-up companies (new) Design of a deferral regime, whereby start-up companies may defer the payment of tax on employee share schemes to a future point in time when the valuation and liquidity problems are not as pronounced.
Social policy
Financial Assistance for Live Organ Donors Bill 2015 Inland Revenue was consulted by the Ministry of Health on aspects that affect the Tax Acts, for example: child support, Working for Families, student loans, KiwiSaver, information sharing, and whether income replacement for donors proposed under the Bill should be treated as income for tax purposes.
Encouraging student loan repayments and addressing debt of overseas-based borrowers in the PEN group Overseas-based student loan borrowers known as the “Penalty (PEN) Group” have overdue amounts growing faster than the rate at which borrowers in this group are becoming compliant. This is due to the compounding effect of late payment penalties (under the 1992 Act) and late payment interest. Ministers are interested in any further measures that could be developed to address the overdue debt of this group and the wider student loan borrower population.
Student loans – interest exemption Budget 2016 announced the International Connections for New Zealanders package, which extends student loan interest write-offs to borrowers studying overseas who are recipients of Government-funded scholarships.
KiwiSaver (new) A range of reforms reflecting recently announced changes to New Zealand Superannuation and the Retirement Commissioner’s recent recommendations.
International tax and base erosion and profit shifting (BEPS)
Hybrid instruments and entities Consideration of foreign hybrid instruments and entities in the context of BEPS.
Double tax agreement (DTA) work programme New Zealand is seeking to establish new and updated double tax agreements with a number of countries, including Norway, China, Korea, Slovak Republic, Portugal and Fiji.
Automatic exchange of information Domestic implementation of a new global standard on the automatic exchange of financial bank account information with treaty partners.
Interest limitation rules Consideration of New Zealand’s interest limitation rules in light of OECD recommendations. Part of the BEPS Action Plan.
Multilateral instrument As part of the BEPS work, the OECD has proposed countries sign a multilateral instrument that will simultaneously amend the double tax agreements of participating countries. The amendments to DTAs will address certain aspects of the BEPS project that have a treaty dimension e.g. treaty shopping or permanent establishment avoidance.
Foreign trust disclosures Policy recommendations arising from the Government Inquiry into foreign trust disclosure requirements.
Inbound investment framework An officials’ paper outlining New Zealand’s approach to taxing foreign investment income has been prepared. It has been used as the basis for targeted consultation with private sector representatives, and has also been published on the tax policy website to facilitate a wide understanding of the trade-offs the Government faces in responding to BEPS.
Business transformation and Better Public Services
Business transformation
Better administration of GST and PAYE Policy options to reduce compliance and administrative costs consistent with longer term business transformation thinking.
Review of the Tax Administration Act Developing a framework for tax administration with an emphasis on the key roles of the Commissioner, taxpayers and tax agents, as well as the rules around information collection and tax secrecy which underpin their interactions.
Individuals’ taxation Improving the tax system for individuals, including comprehensive pre-population of income information, collection of information, more efficient debt collection processes and the degree of interaction with the tax system.
Business taxation Improving the tax system for business, including the calculation of provisional tax, the collection of information and reviewing the penalties and interest rules. Includes researching additional measures that have potential to deliver further benefits to businesses, reduce compliance costs and make the tax system simpler.
Investment income information Streamlining the collection of information about investment income such as interest, dividends, PIE income and Māori authority distributions.
BT social policy Improving the social policy system for individuals and families, including alignment of definitions, reviewing assessment periods to improve accuracy and timeliness of payments, more efficient debt collection and prevention processes, and improving outcomes for customers with special or exceptional circumstances.
Better Public Services
Information sharing agreement between Ministry of Social Development and Inland Revenue Information sharing with Ministry of Social Development to assist in determining entitlements to benefits, social assistance and other services.
Information sharing between MBIE, the Companies Office and Inland Revenue (new) Information sharing between MBIE, the Companies Office and Inland Revenue.


Developing and implementing any Budget initiatives as appropriate.


  • Supporting other policy areas, committees and agencies – Providing support for tax issues that arise out of non-tax Government priorities, such as Treaty of Waitangi settlements.
  • Supporting Ministers – Providing policy advice on issues raised by Ministers.
  • Supporting bills before Parliament


Business transformation Accounting income method determination * November 2016 – February 2017
BT review of the Tax Administration Act December 2016 – February 2017
BT individuals’ taxation April – May 2017
BT social policy July – August 2017
International tax BEPS package including:
  • interest limitation rules
  • hybrid instruments
  • transfer pricing and permanent
    establishment definition
February – April 2017
Enhancements to tax policy
within broad-base,
low-rate tax settings
MSD/IR information sharing November – December 2016
Demergers * November 2016 – January 2017
Impact of case law on the ‘voting interest’
test for corporate trustees *
December 2016 – January 2017
Feasibility expenditure February – March 2017
Taxation of non-bank securitisation vehicles * March – April 2017
Financial arrangement issues March – April 2017
Trust beneficiaries as settlors * April – May 2017
Deductibility of holding costs for revenue
account property
May – July 2017
Income protection insurance July – September 2017
Conferences CA ANZ conference November 2016
SGATAR conference November 2016
IFA conference March 2017
Bills Closely held companies bill enactment December 2016 – March 2017
Business tax and exchange of
information bill enactment
December 2016 – March 2017
Omnibus taxation bill introduced February – May 2017
Other events Multilateral instrument open for signing December 2016 – January 2017
Business transformation stage 1 go live (GST) February – April 2017
Budget May 2017

* Limited consultation | Timeframes are indicative

Previous work programmes:

Page history:

  • Last updated: 16 August 2017
  • Changes made:
    • 16 August 2017 - Updated with new projects since November 2016 (from the 2017 regulatory stewardship stratgey), completed consultation and events were struck out, social policy projects added
    • 18 November 2016 - Minor formatting change (timeline graphic moved before table)
    • 17 November 2016 - Indicative timetable for 2016–17 consultation and events added (and version in a table), timetable added to the printable version of the work programme (for 8 November 2016 version see: PDF (53 KB), DOCX (43 KB)), minor edits
    • 9 November 2016 - Printable version of the tax policy work programme added, page history added.
    • 8 November 2016 - Updated tax policy work programme added, links to previous tax policy work programmes added.