On December 6, 2017 the New Zealand Government introduced a tax bill to counter base erosion and profit shifting by multinational companies into New Zealand's Parliament (the Taxation (Neutralising Base Erosion and Profit Shifting) Bill). The legislation is expected to have its First Reading in Parliament on Tuesday December 12, 2017.


The Bill contains measures which should prevent multinationals from using:

– artificially high interest rates on loans from related parties to shift profits out of New Zealand;

– hybrid mismatch arrangements that exploit differences between countries’ tax rules to achieve an advantageous tax position;

– artificial arrangements to avoid having a taxable presence in New Zealand; and

– related-party transactions to shift profits into offshore group members in a manner that does not reflect the actual economic activities undertaken in New Zealand and offshore.


Click here to be forwarded to the text of the Taxation (Neutralising Base Erosion and Profit Shifting) Bill as introduced into the New Zealand Parliament on December 6, 2017.


Click here to be forwarded to the Commentary on the Taxation (Neutralising Base Erosion and Profit Shifting) Bill.


Furthermore the New Zealand Government also published the following 4 regulatory impact assessments (RIAs). The regulatory impact assessments cover the following topics:

1.   BEPS – transfer pricing and permanent establishment avoidance rules;

2.   BEPS – strengthening our interest limitation rules;

3.   BEPS – hybrid mismatch arrangements; and

4.   Hybrids/NRWT issue.


Click here to be forwarded to the regulatory impact assessments.



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