Snapshot of recent developments

Tax legislation and policy announcements

Long-term Insights Briefing 2026

On 14 April 2026, Inland Revenue published its Long-term Insights Briefing (LTIB) 2026. The LTIB explores how NZ’s tax system can adapt to long-term fiscal pressures from an ageing population – specifically, the need for higher superannuation and health spending. The report concludes that the best solution is to maintain a stable tax base anchored around income tax and GST but with a goal of increasing flexibility to allow future governments to adjust rates as necessary to meet revenue targets. It highlights that the dual pillar system will allow Governments to utilise income tax to achieve equity objectives and GST to efficiently raise substantial revenue.

Consultation on proposed Approved Information Sharing Agreement between Inland Revenue and Ministry of Social Development

On 20 April 2026, Inland Revenue and the Ministry of Social Development (MSD) published a consultation document Enabling MSD to more quickly use PAYE income information provided by Inland Revenue. The proposed change would waive the existing requirement under the Privacy Act 2020 for MSD to give clients 10 working days’ notice to dispute the accuracy of their personal information when an adverse action is taken (such as reducing or stopping a benefit) based on shared information. This change would help avoid overpayments of benefits and reduce the likelihood of client debt. No new information will be disclosed to MSD because of this change. Public consultation closes 29 May 2026.  

Consultation on proposed Approved Information Sharing Agreement between Inland Revenue and New Zealand Customs Service

On 24 April 2026, Inland Revenue and Customs commenced consultation on a proposed Approved Information Sharing Agreement (AISA). The proposed AISA would allow Customs to share border movement information about Working for Families recipients with Inland Revenue to reduce overpayments and resulting debt when families cease to be eligible on departure from New Zealand. It would also replace the current Inland Revenue–Customs information matching agreements for student loans and child support, with a view to moving those existing sharing arrangements into the AISA over time. Submissions close on 5 June 2026.

Inland Revenue technical guidance

Determination: 2026 International tax disclosure exemption

On 31 March 2026, Inland Revenue published determination ITR37: 2026 International tax disclosure exemption. This determination sets out which interests in foreign companies and foreign investment funds for the year ended 31 March 2026 the Commissioner of Inland Revenue does not require a person to disclose for the administration of the international tax rules. The scope of the 2026 disclosure exemption is the same as the 2025 version and applies for the income year corresponding to the tax year ended 31 March 2026.

Draft question we’ve been asked: Income tax – Bare trusts and mortgages

On 31 March 2026, Inland Revenue published draft Question We’ve Been Asked PUB00544: Income tax – Bare trusts and mortgages for consultation. The QWBA confirms that a person can be a bare trustee under s YB 21 of the Income Tax Act 2007 where there is a mortgage over trust property.

Inland Revenue: Tax Information Bulletin - April 2026 (Vol 38, No 3)

On 1 April 2026, Inland Revenue issued their April 2026 Tax Information Bulletin. The TIB covers the following recent tax developments:

Determinations

• AE 26/01: Participating jurisdictions for the CRS applied standard
• CFC 2026/01, 2026/02, 2026/03, 2026/04, 2026/05: Non-attributing active insurance CFC status TOWER Limited
• FDR 2026/01: No FDR method - Daintree High Income Trust – NZD class units
• ITR37: 2026 International tax disclosure exemption

Interpretation statement

• IS 26/01: Income tax – deductibility of repairs and maintenance expenditure – general principles

Revenue alert

• RA 26/01: Failure to pay PAYE deductions to Inland Revenue

Ruling

• BR Prd 26/01: Covenant Trustee Services Limited as trustee of the Goodman Property Trust

Technical decision summary

• TDS 26/02: Discretionary Investment Management Service fees

Product Ruling: Industrial and Commercial Bank of China (New Zealand) Limited

On 14 April 2026, Inland Revenue issued product ruling BR Prd 26/02: Industrial and Commercial Bank of China (New Zealand) Limited.

The ruling considers the Bank’s “mortgage offset” home loan, where interest on the offset portion of the loan is calculated daily by reference to the net position between the loan balance and the credit balance of a linked account (with interest only potentially payable on any excess credit balance). The Commissioner’s view is that the arrangement changes the method of calculating interest on the home loan, but the offset does not of itself give rise to a separate payment or entitlement to interest for tax purposes (other than interest actually credited on any excess balance). The ruling addresses the application of the financial arrangements, RWT, NRWT, AIL and BG 1 provisions. The ruling applies from 1 April 2025 to 31 March 2030, subject to all interest rates for the offset product being arm’s length market rates.

Draft Interpretation Statement: Goods and services tax – Reduced value rule in s 10(6) for supplies of domestic goods and services in commercial dwellings

On 17 April 2026, Inland Revenue published draft Interpretation Statement PUB00511: Goods and services tax – Reduced value rule in s 10(6) for supplies of domestic goods and services in commercial dwellings and an accompanying fact sheet. The Interpretation Statement considers s 10(6) of the GST Act 1985, which provides for a reduced value for a supply of domestic goods and services in a commercial dwelling for more than 4 weeks. This reduced value rule results in an effective GST rate of 9%. The time from which the reduced value applies depends on whether the commercial dwelling is a residential establishment and whether there is upfront agreement that the domestic goods and services will be supplied for more than 4 weeks in total. The Interpretation Statement replaces the guidance given in Tax Information Bulletin Vol 6, No 2, August 1994. Submissions close on 29 May 2026.

Interpretation Statement: Income tax implications of providing sponsorship

On 20 April 2026, Inland Revenue published IS 26/10 Income tax implications of providing sponsorship and accompanying fact sheet. The Interpretation Statement considers the income tax implications for a business that provides sponsorship to an organisation, event, person or cause, where the taxpayer (sponsor) intends that the sponsorship will promote or advertise the business. This replaces IS3229.

Question we’ve been asked: GST – Registered members of unregistered unincorporated bodies

On 22 April 2026, Inland Revenue issued QB 26/01: GST – Registered members of unregistered unincorporated bodies. The QBWA concludes that members cannot claim input tax for (1) their share of costs incurred by the unincorporated body, or (2) contributions paid to the body in most cases; a deduction may arise only in the limited case where a member buys an interest from another member and that transaction is a taxable supply made and acquired in the course of each party’s separate taxable activity (and the interest is not an exempt participatory security in a contributory scheme).

Inland Revenue: New Cryptoassets Overviews page 

On 28 April 2026, Inland Revenue published a new Cryptoassets Overviews page which lists public guidance on the tax treatment of assets, under the headings; income tax issues, issues papers and technical decision summaries.

Tax cases and technical decision summaries

Technical Decision Summary: Sale and subdivision of land (Private Ruling)

On 9 April 2026, Inland Revenue issued TDS 26/03 Sale and subdivision of land. The private ruling considered a staged land subdivision under a sale and purchase agreement (with settlement and payment for each lot occurring over eight stages across eight years) and the effect of a “lowest price” clause intended to set the agreed price as the “lowest price” for the purposes of s EW 32(3) of the Income Tax Act 2007. Although the SPA was a financial arrangement under s EW 3, Inland Revenue accepted that the relevant “lowest price” value of the land for s EW 32(3) purposes was the purchase price agreed in the SPA, so no financial arrangement income or loss arose under subpart EW.

Disputant’s claim struck out due to failure to follow the disputes process

On 16 April 2026, Inland Revenue issued case summary CSUM 26/02: Disputant’s claim struck out due to failure to follow the disputes process. The Taxation Charities Review Authority struck out the disputant’s challenge to assessments for the 2014–2016 income tax years on the following bases:

• That the Commissioner’s Notice of Proposed Assessment (NOPA) was validly served at the disputant’s recorded contact address under s 14F of the Tax Administration Act.
• No Notice of Response (NOR) was issued within the statutory response period (so the disputant was deemed to have accepted the proposed adjustments and the precondition to challenge under s 138B was not met).
• There were no “exceptional circumstances” justifying an extension of time (including to challenge the Commissioner’s refusal to accept a late NOR).

The Authority also noted that refusals to amend assessments are excluded from challenge under s 138E, and held it had no jurisdiction to hear the claim - including on the procedural fairness arguments raised.

Taxpayers’ appeal against evasion shortfall penalties dismissed

On 16 April 2026, Inland Revenue issued case summary CSUM 26/03: Taxpayers’ appeal against evasion shortfall penalties dismissed. The High Court dismissed an appeal by six taxpayers against the Taxation Charities Review Authority’s decision to uphold evasion shortfall penalties, arising from their New Zealand vehicle dismantling/export business and substantial remittances (around $6.4m) received from a related UAE entity. The taxpayers had returned relatively modest income (and claimed Working for Families tax credits) and contended the remittances related to overseas land/timber sales and loans, with the UAE account used as a conduit. However, the Court held the Authority was entitled to find that the taxpayers had intentionally evaded tax, based on (1) the scale and pattern of the remittances, (2) the absence of adequate records, and (3) the Authority’s adverse credibility findings.

Inland Revenue media release and operational updates

Inland Revenue: Automated voice messages for overdue tax and late tax returns

On 31 March 2026, Inland Revenue announced that they will be continuing to follow up with taxpayers who have overdue tax payments or returns. Taxpayers will receive a prerecorded call from an ID that shows as “Inland Revenue” and the number 0800 951 758 will display on their phone.

Inland Revenue: Tax agents’ extension of time (EOT) agreement 

On 1 April 2026, Inland Revenue published the tax agents’ extension of time (EOT) agreement - IR9XA for the 1 April 2026 to 31 March 2027 year. The guidelines set out filing targets and expectations to support tax agents to meet their extension of time commitments.

Inland Revenue: Two-step verification (2SV) helps contain cyber attack

On 2 April 2026, Inland Revenue published a media release detailing how two-step verification (2SV) has prevented most of the 500,000 attempts by cyber criminals trying to access myIR accounts in the previous month. 300 accounts that did not have 2SV verification set up were accessed in cyber-attacks. Inland Revenue have closed these accounts and will contact the affected customers. Inland Revenue believe that the taxpayers had used the same credentials (username and password) on their myIR account as they use on other, less secure, sites. Username and password combinations from less secure systems are frequently distributed and sold online, highlighting the importance of using unique passwords for every site.

Inland Revenue: Information release – compliance activities

On 10 April 2026, Inland Revenue published an information release report to Ministers on Inland Revenue’s preliminary assessment of the direct effects of compliance activities. The report is a condition of Budget 2025 funding for developing Inland Revenue’s internal capability to assess, based on international best practice, the direct and indirect effects of compliance activities.

Inland Revenue: Cyclone Vaianu

On 13 April 2026, Inland Revenue published advice that if taxpayers have been affected by Cyclone Vaianu they do not need to immediately contact Inland Revenue, but when they do contact Inland Revenue to use the word “weather” in myIR.

Inland Revenue: Expanding decision support collection actions

On 14 April 2026, Inland Revenue announced that effective from 16 April 2026, the wage and salary deduction process will include deductions on schedular payments. This means taxpayers with outstanding debt and income from these sources may have deductions applied. Including income source deductions in their collections processes means Inland Revenue can act earlier and more consistently.

Incorporated societies – important information for societies that have been removed from the register

On 14 April 2026, Inland Revenue announced that they will be emailing incorporated society taxpayers who were removed from the register for failing to re-register on time. Inland Revenue will email the taxpayer’s linked tax agent when they cannot contact the taxpayer directly.

Inland Revenue: Crypto investors urged to get tax compliant

On 20 April 2026, Inland Revenue issued a reminder to crypto-asset investors that profits made from selling, trading or exchanging crypto-assets are generally taxable, and therefore investors should ensure they comply with their tax obligations. Increased data from the new CARF framework will give Inland Revenue more visibility over crypto-asset transactions that occur overseas where New Zealand tax residents are involved. Inland Revenue have sent out their first batch of letters to people who have traded crypto-assets and would normally have their tax assessed automatically.

Inland Revenue: Tax Agent debt webinar April 2026

On 21 April 2026, Inland Revenue uploaded the slides from their recent Tax Agent debt webinar.

Inland Revenue: Changes to sharing information about unpaid tax

On 22 April 2026, Inland Revenue announced that they have changed how they share information about unpaid tax to credit agencies. Inland Revenue can now disclose unpaid tax to credit agencies after at least two automated overdue notices, without needing direct contact with the taxpayer. It has also streamlined the notice process and may extend disclosures to other approved credit reporting agencies.

Inland Revenue: Determination – Wellington severe weather event

On 28 April 2026, Inland Revenue published Determination 26/03 Declaration that the Wellington severe weather event in April 2026 is an emergency event for the purposes of family scheme income. 

International updates

Historic NZ-India FTA signed in New Delhi

On 27 April 2026, the Prime Minister announced the signing of the Free Trade Agreement between New Zealand and India. The agreement was concluded in December and eliminates or reduces tariffs on 95% of NZ’s exports – among the highest of any Indian FTA.

Signing activates the standard parliamentary process, allowing Parliament and the public to scrutinise the agreement through the Select Committee. The FTA text and National Interest Analysis will be tabled in Parliament and referred to the Foreign Affairs, Defence and Trade Committee (FADTC).  Once FADTC has completed its examination, enabling legislation will be introduced and will follow the usual legislative process.

Australia: Federal Budget 2026-27 tax webinar

On 13 May 2026 at 1pm (NZT), a panel of Tax Partners at Deloitte Australia will be presenting a webinar on the Federal Budget for 2026-27. The panel will provide their perspectives and actionable insights on this year’s Federal Budget announcements. Taxation reform is expected to centre around better incentivising productive business investment, intergenerational equity, sustainability, and simplicity. Please follow this link to register for the webinar.

OECD updates

Foundations for Growth and Competitiveness

On 9 April 2026, the OECD published an article on the release of their first edition of Foundations for Growth and Competitiveness. The report highlights the urgent need to revive reform momentum, take action to reignite the structural drivers of growth and ensure that economies remain competitive and resilient in a rapidly transforming global landscape.

Secretary-General Tax Report to the G20

On 16 April 2026, the OECD published its OECD Secretary‑General Tax Report to G20 Finance Ministers and Central Bank Governors. The report sets out recent developments in international tax co-operation, including the OECD’s support of G20 priorities such as the implementation of the BEPS minimum standards, the global minimum tax framework and the Side-by-Side package, and tax transparency.

Taxing Wages 2026

On 22 April 2026, the OECD announced the publication of their new Taxing Wages 2026 report. The report provides cross-country comparisons of the labour tax wedge, which shows total taxes on labour paid by employees and employers, minus cash benefits received by working families, as a percentage of labour costs. The report concludes that on average across the OECD, the tax wedge for all eight household types examined in the report increased in 2025 to reach their highest level since 2018. However, it also reveals that wages rose in real terms in 35 out of 38 OECD countries in 2025.

A Practical Guide to Investment Tax Incentives

On 27 April 2026, the OECD published their report A Practical Guide to Investment Tax Incentives. The guide supports governments, particularly in developing and emerging economies, to better design and implement investment tax incentives. It provides concrete guidance across the policy lifecycle, from conception, to design, implementation, monitoring and evaluation. At each stage, the guide highlights key decision points and practical policy options to improve outcomes and support prioritisation of reforms, drawing on lessons from country experiences worldwide.

Note: The items covered here include only those items not covered in other articles in this issue of Tax Alert.