International Secondments and Corporate Residency: Care and Diligence Bring Luck

New Zealand Tax Planning Report, no 2, May 2012.

9 Pages Posted: 12 Jul 2012 Last revised: 1 Aug 2012

See all articles by Craig Elliffe

Craig Elliffe

University of Auckland - Faculty of Law

Date Written: May 12, 2012

Abstract

This paper considers two recent NZ Taxation Review Authority cases concerning residency. One case looks at the tie-breaker provisions of the dual residency rules in Article 4 of the New Zealand/ Fiji Double Tax Convention while the other looks at the corporate residency test in New Zealand domestic law.

Keywords: residency, dual residency, permanent home, centre of vital interests, management and control

JEL Classification: K34

Suggested Citation

Elliffe, Craig Macfarlane, International Secondments and Corporate Residency: Care and Diligence Bring Luck (May 12, 2012). New Zealand Tax Planning Report, no 2, May 2012., Available at SSRN: https://ssrn.com/abstract=2104027 or http://dx.doi.org/10.2139/ssrn.2104027

Craig Macfarlane Elliffe (Contact Author)

University of Auckland - Faculty of Law ( email )

Private Bag 92019
Auckland Mail Centre
Auckland, 1142
New Zealand

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