Source: The Tax Specialist Journal Article
Published Date: 1 Feb 2020
Like Australia, New Zealand has enthusiastically adopted a range of measures in response to the OECD's recommendations concerning base erosion and profit shifting. Of these, the New Zealand reform that is most complex and has the greatest potential to result in unintended outcomes is the introduction of anti-hybrid rules. New Zealand's anti-hybrid rules were enacted in June 2018 with application to income years commencing on or after 1 July 2018. This article highlights some of the differences in tax treatment between the New Zealand and Australian tax systems that may give rise to a hybrid mismatch, before considering a series of practical examples illustrating how the anti-hybrid rules may affect a range of common arrangements. As the examples illustrate, although both New Zealand's and Australia's anti-hybrid measures are based on the same OECD recommendations, the rules differ
in important respects and may produce unexpected consequences in some cases.
New Zealand developments affecting M&A transactions - Journal 01 Oct 2021
The ever-increasing reach of New Zealand's general anti-avoidance rule - Journal 01 Sep 2014
New Zealand tax on inbound foreign direct investment: The good, the bad and the ugly - Journal 01 Apr 2013
The New Australia-New Zealand DTA - Journal 01 Apr 2010
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