Alesco New Zealand Limited v CIR: Concerns Over the Broad Discretion in the Application of the New Zealand GAAR
British Tax Review, No 3, 2013
13 Pages Posted: 6 Aug 2013
Date Written: July 4, 2013
Abstract
This note discusses the Court of Appeal decision in Alesco NZ, the most recent application of the New Zealand general anti-avoidance rule to a cross border hybrid instrument.
Keywords: general anti-avoidance rule, New Zealand, cross border instrument, hybrid instrument, optional convertible note
JEL Classification: K34
Suggested Citation: Suggested Citation
Elliffe, Craig Macfarlane and Keating, Mark, Alesco New Zealand Limited v CIR: Concerns Over the Broad Discretion in the Application of the New Zealand GAAR (July 4, 2013). British Tax Review, No 3, 2013, Available at SSRN: https://ssrn.com/abstract=2305866
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