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
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: 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
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