Download or read book The New Zealand Controlled Foreign Company Regime written by John Prebble QC and published by . This book was released on 2015 with total page 15 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the late 1980s New Zealand signaled its intention to pass legislation to prevent resident shareholders from using controlled foreign companies to avoid tax. Controlled foreign companies all operate in a similar fashion. The regimes apply to non-resident companies that are owned or controlled by residents of the country that enacts the regime, and the rules apply to these resident owners or controllers, who are ordinarily shareholders in the companies in question.
Download or read book Costs of Compliance with the New Zealand Controlled Foreign Company Regime written by John Prebble QC and published by . This book was released on 2015 with total page 17 pages. Available in PDF, EPUB and Kindle. Book excerpt: Controlled foreign company regimes are sets of anti-avoidance rules. These regimes assist in preventing companies from diverting income through tax havens. Such regimes require the parent company to report the income of its subsidiary for New Zealand tax purposes as if it were its own. Complying with these regimes incurs costs. In 1991, a survey was commissioned to uncover the costs of compliance. The results were reported in this article.
Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Download or read book New Zealand Company Taxation written by John Prebble KC and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since 1988, New Zealand has employed a full imputation system for the taxation of companies. That is, all tax paid at the corporate level can be imputed to shareholders when companies distribute dividends. The intention is that company profits should bear tax once only, not twice. Companies are obliged to keep a memorandum account in addition to their regular accounts, called the “imputation credit account”. Rules governing the imputation credit account prevent companies from imputing to shareholders the benefit of tax that the company has not in fact paid and frustrate other forms of avoidance. Dividends from foreign companies that are received by individuals are assessable in their hands, with credit for withholding tax. Similarly, New Zealand has had a controlled foreign company regime since 1988. The regime has two philosophies: to combat avoidance by use of tax havens, and to promote capital export neutrality.
Download or read book New Zealand s Controlled Foreign Company Regime written by Howard Baxter Davey and published by . This book was released on 1995 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Use of Discretionary Trusts to Minimise the Income Tax Liability of Immigrants to New Zealand Under the Controlled Foreign Companies Regime written by Timothy Gray Cameron and published by . This book was released on 1994 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treaties and Controlled Foreign Company Legislation Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Download or read book Circumventing the Controlled Foreign Company and Investment Fund Regimes in Australia and New Zealand written by Philip Barclay Gurney and published by . This book was released on 2004 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book CFC Legislation Tax Treaties and EC Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
Download or read book International and Cross border Taxation in New Zealand written by Craig Elliffe and published by . This book was released on 2018 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by international tax law specialist Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand's international tax law and double taxation agreements and transfer pricing regime. The book is designed to provide readers with an understanding of the legal principles and concepts which underpin international tax law and cross-border transactions and with practical guidance designed to assist them to navigate their way through this complex topic. It begins with an introductory chapter explaining the history and concept of international taxation and the way in which New Zealand and other nations deal with international taxation transactions. The next four chapters provide comprehensive coverage of residence-base taxation; source-based taxation; and taxation of source based income. The final two chapters deal with double tax agreements and allocation of profits (thin capitalisation).
Download or read book OECD G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules Action 3 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Download or read book Lin V Commissioner of Inland Revenue 2018 NZCA 38 written by and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Judgment by the Court of Appeal of New Zealand, judgment date 8 March 2018. In a recently released decision, Lin v CIR, the High Court found that tax relief under the New Zealand - China Double Tax Agreement is available for tax payable under the controlled foreign company (CFC) regime, and that New Zealand tax credits are available for tax paid by a CFC in China and also for tax spared in China. The Court of Appeal has allowed an appeal by the Commissioner of Inland Revenue (CIR) from a High Court decision. The Court held that a New Zealand resident is not entitled to a credit against income tax liability in New Zealand for tax spared by China on income earned by companies in which the resident had an income interest.
Download or read book New Zealand s 1988 International Tax Regime for Trusts written by John Prebble QC and published by . This book was released on 2015 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the late 1980s New Zealand undertook a process of adopting a new income tax regime for companies, and in particular for controlled foreign companies. The new rules reflected a change from a classical to an imputation system. The rules were designed to frustrate avoidance deferral that was previously achievable by residents through the use of controlled foreign companies. Coupled with the introduction of this reform was a new regime for the taxation of trusts, reflecting the fact that trusts are often employed as substitutes for companies.
Download or read book International tax reform Full imputation Part 2 Volume 1 written by Consultative Committee on Full Imputation and International Tax Reform and published by The Treasury, New Zealand. This book was released on 1988-07-31 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: The final report of the Consultative Committee on Full Imputation and International Tax Reform. Volume 1 contains recommendations on the further detailed measures required for the operation of the imputation and international tax regimes. Volume 2 sets out the draft legislation.
Download or read book Doing Business 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-21 with total page 241 pages. Available in PDF, EPUB and Kindle. Book excerpt: Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.
Download or read book Multinational Enterprises the Law written by Peter T. Muchlinski and published by OUP Oxford. This book was released on 2007-07-12 with total page 856 pages. Available in PDF, EPUB and Kindle. Book excerpt: Multinational Enterprises and the Law presents the only comprehensive contemporary and interdisciplinary account of the various techniques used to regulate multinational enterprises (MNEs) at the national, regional and multilateral levels. In addition it considers the effects of corporate self-regulation upon the development of the legal order in this area. Split into four parts the book firstly deals with the conceptual basis for MNE regulation, explaining the growth of MNEs, their business and legal forms and the relationship between them and the effects of a globalising economy and society upon the evolution of regulatory agendas in the field. Part II covers the main areas of economic regulation including the limits of national and regional jurisdiction over MNE activities, controls, and liberalization of entry and establishment, tax, company, and competition law. Part III introduces the social dimension of MNE regulation covering labour rights, human rights, and environmental issues, and Part IV deals with the contribution of international law and organizations to MNE regulation and to the control of investment risks, covering the main provisions found in international investment agreements and their recent interpretation by international tribunals.
Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by Cambridge University Press. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
