New Zealand Branch Report, Subject 1: Assessing BEPS: Origins, Standards and Responses

FA 2017 Rio de Janeiro Congress

32 Pages Posted: 30 Nov 2016

See all articles by Craig Elliffe

Craig Elliffe

University of Auckland - Faculty of Law

Carmel Peters

Independent

Peter Vial

Independent

Date Written: November 28, 2016

Abstract

Assessing BEPS

The government has reviewed New Zealand’s current policy settings and determined that most are robust and fit for purpose. Having identified hybrid mismatch arrangements, interest allocation and transfer pricing as issues that may need addressing, it is developing and refining its proposed response. It is also monitoring BEPS-related reforms in other jurisdictions, particularly Australia.

The government is consulting with the public including business groups on proposed reforms to New Zealand domestic law and on changes resulting from New Zealand’s adoption of revised international rules and guidance. The private sector is actively engaged with the government on the New Zealand response.

It is early days yet, in the sense that domestic legislative reform relating to, for example, interest allocation and hybrid arrangements is still to be confirmed. Business is concerned at the risk of complexity and over-reach and, more broadly, the effect such reforms may have on inbound investment and taxpayers’ cost of capital. It is also concerned that New Zealand will get ahead of, or out of alignment with, its major trading partners in the adoption of anti-BEPS measures. From the private sector’s perspective the effectiveness of the generic tax policy process is likely to be tested in 2017 as BEPS related legislative reform is introduced and enacted.

Suggested Citation

Elliffe, Craig Macfarlane and Peters, Carmel and Vial, Peter James, New Zealand Branch Report, Subject 1: Assessing BEPS: Origins, Standards and Responses (November 28, 2016). FA 2017 Rio de Janeiro Congress, Available at SSRN: https://ssrn.com/abstract=2876867 or http://dx.doi.org/10.2139/ssrn.2876867

Craig Macfarlane Elliffe (Contact Author)

University of Auckland - Faculty of Law ( email )

Private Bag 92019
Auckland Mail Centre
Auckland, 1142
New Zealand

Carmel Peters

Independent ( email )

Peter James Vial

Independent

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