Published on 01 Jul 97
by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE
For many years the NZ tax regime has imposed high effective tax rates on income earned by NZ resident companies controlled by non-resident investors. This gave rise to significant incentives for non-resident investors to avoid NZ tax by adopting income shifting arrangements such as transfer pricing and thin capitalisation. NZ tax law has generally contained few provisions to attach such arrangements. This article examines the current situation.