Inland Revenue: Determination of expenditure incurred relating to payments made by New Zealand Clinical Research to volunteers

On 29 April 2025, Inland Revenue issued DET 25/02: Determination of expenditure incurred relating to payments made by New Zealand Clinical Research to volunteers. This determination applies to payments made by New Zealand Clinical Research Group (NZCR) to people who volunteer to participate in clinical medical trials run by NZCR. The determination applies for the period 1 April 2025 onwards and applies to set an amount of expenditure, up to a maximum of $150, for which each payment made by NZCR to participants is a reimbursement of actual expenses incurred by the volunteer.

National Average Market Values of Specified Livestock Determination 2025

On 26 May 2025, Inland Revenue issued NAMV 2025: National Average Market Values of Specified Livestock Determination 2025. For the purpose of section EC 15, the national average market value of specified livestock for the 2024-25 income year is set out in the determination.

Tax Information Bulletin: June 2025

On 3 June 2025, Inland Revenue issued TIB Vol 37, No 5 (June 2025), which includes the following:

New legislation

• Public Act 2025 No 09: Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025
• SL 2025/64: Income Tax (Fringe Benefit Tax, Interest on Loans) Amendment Regulations 2025
• SL 2025/65: Taxation (Use of Money Interest Rates) Amendment Regulations 2025             

Operational statements

• OS 25/03: Authority to Act for Tax Agents, Representatives and Nominated Persons: Access to a Client’s Inland Revenue Information  

Interpretation statements

• IS 25/14: Income tax - arrangements involving tax losses carried forward under the business continuity rules
• IS 25/15: Look-through companies and disposal of residential land under the bright-line test         

Questions we've been asked

• QB 25/07: What is the income tax treatment of gift cards and products provided as trade rebates or promotions?
• QB 25/08: When is land acquired for a purpose or with an intention of disposal so that the amount derived from the sale is income?
• QB 25/09: When do I have a “regular pattern” of transactions that prevents me from using exclusions from the land sale rules for my residence or for my main home?
• QB 25/10: On what date is a person treated as acquiring land for the purposes of the land sale rules?
• QB 25/11: When is the bright-line start date for the 2-year bright-line test?
• QB 25/12: How does the bright-line test apply to the sale of a subdivided section?
• QB 25/13: When is the sale of a lifestyle block excluded from the bright-line test?
• QB 25/14: When does the business premises exclusion to the bright-line test apply?
• QB 25/15: How do the bright-line rollover relief provisions apply to transfers of residential land between associated persons?

Case summaries

• CSUM 25/05: NZTCRA rejects argument that an interest amount paid under a relationship property agreement was deductible as an expense under the Income Tax Act 2007
• CSUM 25/06: NZTCRA finds work to convert retail space to office space in commercial building was capital in nature
• CSUM 25/07: NZTCRA finds remediation work on unit was capital in nature

Technical decision summaries

• TDS 25/08: Disposal of shares following amalgamation
• TDS 25/09: Distribution and resettlement of trusts
• TDS 25/10: Source of income and foreign tax credits
• TDS 25/11: Deductions, zero-rating and shortfall penalties
• TDS 25/12: Deductions and shortfall penalties            

Inland Revenue: Extra funding to support more compliance work

On 4 June 2025, Inland Revenue outlined how will use increased funding in this year’s budget to boost collection activities and invest more in tax compliance.

Inland Revenue will use the additional funding to focus on new activities around things like:

• further increasing audits and debt collection in areas of high risk and/or value
• investigations into specific sectors such as property, organised crime, the hidden economy and trusts
• improved use of data and intelligence to more quickly identify and target discrepancies and pursue debt
• shifting from a manual to an automated process to collect data from third parties, such as banks
• investigating more targeted compliance activity measures.

Draft Interpretation Statement: Student Loans – Overseas borrowers and their obligations

On 6 June 2025, Inland Revenue issued: PUB00497: Student Loans – Overseas borrowers and their obligations. It discusses when a student loan borrower will be a New Zealand-based borrower and when they will be an overseas-based borrower. A borrower’s status as New Zealand-based or overseas-based will determine whether interest accrues on their loan and will impact their repayment obligations. The deadline for comment has closed. 

Inland Revenue: Updated Public Guidance work programme

On 9 June 2025, issued an updated public guidance work programme. This records the public guidance projects that Inland Revenue’s Tax Counsel Office are working on.

Inland Revenue: 2025 CPI adjustment to standard-cost amounts for household services

On 9 June 2025, Inland Revenue published the CPI adjustments to the standard-cost amounts for the 2025 income year, reflecting the annual movement of the CPI of 2.5%

• DET 09/02 (CPI 2025): 2025 CPI adjustment for Determination DET 09/02: Standard-cost household service for childcare providers
• DET 19/01 (CPI 2025): 2025 CPI adjustment to DET 19/01: Household boarding service providers
• DET 19/02 (CPI 2025): 2025 CPI adjustment to DET 19/02: Short-stay accommodation

Inland Revenue: 2025 CPI adjustment for square metre rate for the dual use of premises

On 9 June 2025, Inland Revenue published the CPI adjustment for OS 19 03 (CPI 2025): 2025 CPI adjustment to Operational Statement OS 19/03: Square metre rate for the dual use of premises.

Inland Revenue: Square metre rate for home office calculations 2025

On 10 June 2025, Inland Revenue announced the square metre rate for home office calculations has been set at $55.60 for the 2025 income year (1 April 2024 to 31 March 2025).

Inland Revenue: Tax agent survey results (Jan-Mar 2025)

On 11 June 2025, Inland Revenue announced the survey results of the January-March 2025 Tax Agents Voice of the Customer (TAVOC) survey.

Inland Revenue: Determination relating to per diem allowances paid in the screen production industry

On 11 June 2025, Inland Revenue issued DET 25/03: Determination of amount of a particular payment (being per diem allowances paid in the screen production industry) that shall be regarded as expenditure incurred relating to those payments. Where any resident or non-resident contractor, or resident or non-resident entertainer receives a per diem allowance in relation to services provided to a screen production while working away from their town of normal residence and that allowance is a schedular payment, the sum of $100 per day shall be regarded as expenditure incurred in the production of the payment. If the total amount of the payment is less than $100 per day, the total amount of the payment shall be regarded as expenditure incurred in the production of the payment.

Inland Revenue: Decision Support Collections Tool live now

On 17 June 2025, Inland Revenue advised that they had launched a new analytical tool to support collections activity. The tool analyses taxpayer information and provides tailored recommendations for Inland Revenue to take the right action at the right time, based on each taxpayer’s situation.

Inland Revenue: Update on issue – Progress on debit interest charged from the terminal tax due date on provisional tax

On 17 June 2025, Inland Revenue announced the remediation work they have been doing doing to address the issue of debit interest being charged on provisional tax from the wrong due date has been progressing. Most accounts have been fixed, and the remaining ones are on track to be updated in the coming few weeks.  

A small group of taxpayers are also affected by some other provisional tax issues which Inland Revenue identified from 17 March. These are being managed in line with standard processes, and work is ongoing to resolve them.

Inland Revenue: No change to FBT rules for double cab utes

On 17 June 2025, Inland Revenue issued a statement to clear up a misunderstanding by some commentors about the effect of new FBT proposals, particularly those for double cab utes. Inland Revenue Deputy Commissioner (Policy) David Carrigan says it’s a myth that utes have always been FBT free.

Carrigan also noted “The government has not made any final decisions in relation to potential changes to the FBT regime and Ministers are currently considering the feedback received from submitters on the Inland Revenue issues paper with a view to refining those proposals.”

Inland Revenue: Problem gambling levy change

On 18 June 2025, Inland Revenue announced that the new problem gambling levy applies from 1 July 2025 and replaces the old levies. The levies are set every 3 years.

Inland Revenue: Horticulture sector in the spotlight

On 18 June 2025, Inland Revenue announced it is seeing a few concerning practices in the horticulture sector, including people being paid under the table. In the past 10 months Inland Revenue has found $45m of undeclared tax in the horticulture industry.

Inland Revenue: Paid parental leave rate change

On 23 June 2025, Inland Revenue issued an update on the paid parental leave rates. From 1 July 2025, eligible employees and self-employed people will see an increase in the parental leave payment from $754.87 to $788.66 each week before tax. The minimum rate for self-employed people will increase from $231.50 to $235.00 each week, which is equal to 10 hours worked each week at the adult minimum wage.

Operating Statement: The Commissioner of Inland Revenue’s search powers

On 30 June 2025, Inland Revenue published OS 25/04 The Commissioner of Inland Revenue’s search powers. The statement outlines the procedures the Commissioner of Inland Revenue will generally follow when exercising the Commissioner of Inland Revenue’s search powers under sections 17, 17C and 17D of the Tax Administration Act 1994 and the Search and Surveillance Act 2012.

Operating Statement: Section 17B Notices

On 30 June 2025, Inland Revenue published OS 25/05: Section 17B Notices. The statement outlines the procedures the Commissioner of Inland Revenue will generally follow when issuing notices, including to third parties, under s17B of the TAA 94. 

Public Guidance Work Programme updated

On 30 June 2025, Inland Revenue issued an updated Public Guidance work programme. This is the final work programme for the Inland Revenue financial year.

Inland Revenue: Flooding – Nelson, Tasman and Marlborough

On 30 June 2025, the Minister of Agriculture and Minister for Rural Communities declared a medium scale adverse event for the Nelson, Tasman and Marlborough regions as a result of flooding. 

To help affected farmers and growers Inland Revenue have made a “class of case” determination for the Income Equalisation Scheme to allow:

• Late deposits for the 2025 income year up to 31 May 2026.
• Early withdrawals if the deposit was made prior to the Ministerial announcement on 30 June 2025.

More information about this event and the help available to farmers and growers is available here.

If contacting Inland Revenue, in myIR use the subject ‘June flooding’ or call on the disaster line 0800 473 566.

Tax Information Bulletin: July 2025

On 1 July 2025, Inland Revenue issued the Tax Information Bulletin for July 2025, which includes the following:

Determinations

• NAMV 2025: National Average Market Values of Specified Livestock Determination 2025
• OS 19 04 (KM 2025): Kilometre rates for the business use of vehicles for the 2025 income year
• 2025 Consumers Price Index adjustment to standard-cost amounts for household services (childcare, boarding services, or short-stay accommodation)
• 2025 CPI adjustment to Operational Statement OS 19/03: Square metre rate for the dual use of premises
• Det 25/02: Determination of expenditure incurred relating to payments made by New Zealand Clinical Research to volunteers
• Det 25/03: Determination of amount of a particular payment (being per diem allowances paid in the screen production industry) that shall be regarded as expenditure incurred relating to those payments

Ruling

• BR Prd 25/03: Extraordinary Pay Limited

Interpretation statements

• IS 25/16: Tax residence
• IS 25/17: Tax residence – government service rule

Question we’ve been asked

• QB 25/16: Income tax – How do the income tax rules apply when a close company provides short-stay
  accommodation?

Case summaries

• CSUM 25/08: Absence of evidence makes it impossible to prove nexus with the expenditure and the claimed deductions
• CSUM 25/09: Lack of complete financial records secures TCRA win for the Commissioner in major income suppression case

Technical decision summaries

• TDS 25/13: Income tax – land transferred within a consolidated tax group
• TDS 25/14: Business restructure

Inland Revenue: Two-step verification compulsory for all myIR users by 5 October 2025

On 2 July 2025, Inland Revenue announced two-step verification will be compulsory for all myIR users by 5 October 2025, in the following stages:

• 28 July 2025 – Individual taxpayers who file IR3 returns and customers who pay provisional tax
• 25 August 2025 – Individual taxpayers who are registered for any of the following: paid parental leave, Working for Families Tax Credits, child support and FamilyBoost
• 5 October 2025 – All remaining taxpayers

Inland Revenue: Income for FamilyBoost

On 7 July 2025, Inland Revenue provided an update on FamilyBoost processing. FamilyBoost entitlement depends on family income. Inland Revenue need both parents’ returns to be filed before they can work out entitlements.

Inland Revenue: Claiming Investment Boost – how to include in income tax returns

On 11 July 2025, Inland Revenue advised claimed Investment Boost should be recorded the same as depreciation and included in the Financial statements summary - IR10, or attached financial accounts. For example, if you buy a new asset for $10,000 on 23 May 2025, include the Investment Boost amount of $2,000 (20%) as depreciation in Box 52 of the Financial statements summary - IR10.

Questions we’ve been asked: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset?

On 11 July 2025, Inland Revenue issued QB 25/17: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset? The answer is no as the capital limitation in section DA 2(1) prevents you from claiming a deduction because the expenses are of a capital nature. However, where the capital asset is an item of depreciable property, you may be able to claim a depreciation loss based on the amount of the expenses.

Questions we’ve been asked: Does GST apply to a deposit the seller retains in a cancelled land sale agreement?

On 15 July 2025, Inland Revenue issued QB 25/18: Does GST apply to a deposit the seller retains in a cancelled land sale agreement? It replaces ‘GST consequences of a cancelled contract TIB Vol 17, No 4 (May 2005): 26’. The answer is that no, GST does not apply to the deposit because the seller makes no supply of land or any other supply in return for the deposit.

Inland Revenue: 2025 Child support payments - receiving carers

On 16 July 2025, Inland Revenue provided a table of child support payment dates through to December 2025.

Inland Revenue: Determination the FDR method may not be used by investors in the iShares Global Aggregate Bond ESG SRI UCITS ETF – EUR hedged (Accumulating) share class

On 17 July 2025, Inland Revenue issued FDR 2025/05: Determination the fair dividend rate method may not be used to calculate FIF income by investors in the iShares Global Aggregate Bond ESG SRI UCITS ETF – EUR hedged (Accumulating) share class.  Any investment by a NZ resident investor in the EUR hedged (Accumulating) share class of the iShares Global Aggregate Bond ESG SRI UCITS ETF (ISIN IE000APK27S2), a sub-fund of iShares III Public Limited Company (iShares III), to which none of the exemptions in ss EX 29 to 43 of the Income Tax Act 2007 apply, is a type of attributing interest for which the investor may not use the FDR method to calculate FIF income for the interest when the investment is hedged to NZD by the NZ resident investor.

Inland Revenue: Total income not liable for ACC earners' levy - field not pre-populating

On 22 July 2025, Inland Revenue announced they had found an error where the total income not liable for ACC earners’ levy field was not pre-populating in IR3 web returns that was fixed on 1 July. Since then, income tax returns filed in myIR have not been affected. Inland Revenue are correcting income tax returns for taxpayers. The updated returns will show the correct amount of earnings not liable for ACC.

Inland Revenue will send a notification in myIR to the web logon that submitted the return, advising when Inland Revenue have updated the tax position. If a tax agent filed the return, they will get the notification. If a taxpayer filed the return, they will get the notification directly. For a small group of taxpayers, Inland Revenue will need more time to correct their returns. 

Inland Revenue: Claiming Investment Boost – update

On 23 July 2025, Inland Revenue announced that for the 2025 tax year, businesses should record Investment Boost in their income tax returns in the same way as depreciation. 2025 Income tax return forms have already been published, and many have already been filed. Inland Revenue are currently working on how businesses should record these amounts for the 2026 and future tax years.  Inland Revenue will provide more guidance when details are finalised.

Draft Interpretation Statement: Income tax - business activity

On 24 July 2025, Inland Revenue published PUB00478: Income tax – business activity. This interpretation statement gives guidance on whether and when a taxpayer is carrying on a “business” for income tax purposes. This is relevant to whether a person has income from a business under section CB 1 and to other provisions in the Income Tax Act 2007 where carrying on a business is a requirement. The deadline for submissions is 5 September 2025.

Draft Question we’ve been asked: Can a farmer who leases land deduct the tax book value of horticultural plants on the land when the lease ends?

On 4 August 2025, Inland Revenue issued PUB00491: Can a farmer who leases land deduct the tax book value of horticultural plants on the land when the lease ends? The lessee farmer cannot deduct the remaining diminished value of the expenditure in the income year the lease ends. The ability to deduct the remaining diminished value of the plants is passed to the landowner farmer in the income year the lease ends. The lessee farmer is allowed an amortisation-like deduction in each income year for expenditure on planting horticultural plants on land leased by that farmer, except in the income year in which the lease ends and they cease to carry on a farming business on the land. If after the end of the lease the landowner carries on a farming business on the land with the plants, the landowner farmer assumes the lessee farmer’s tax book values for the horticultural plants in the income year the lease ends and continues the annual amortisation-like deduction of the plants. The deadline for submissions is 15 September 2025.

Draft Question we’ve been asked: Do the purchase price allocation rules alter the tax book values of Farmland Improvements and listed horticultural plants under subpart DO?

On 4 August 2025, Inland Revenue issued PUB00492: Do the purchase price allocation rules alter the tax book values of Farmland Improvements and listed horticultural plants under subpart DO? The answer is no, the purchase price allocation rules in sections GC 20 and GC 21 do not override the rules in subpart DO that specify the tax treatment of Farmland Improvements and listed horticultural plants. Under subpart DO, if the purchaser carries on a farming business on the farmland the purchaser assumes the seller’s tax book values for the improvements and plants in the year of the sale and continues the annual amortisation-like deduction of the improvements and plants. The deadline for submissions is 15 September 2025.

Draft Interpretation Statement: GST – Meaning of payment

On 28 July 2025, Inland Revenue issued PUB00520: GST – Meaning of payment. This interpretation statement discusses the meaning of “payment” for GST purposes. The meaning of payment is relevant for determining the time of supply, the tax period for which you return output tax or for which you claim an input tax deduction, and eligibility for a secondhand goods input tax deduction. The deadline for submissions is 10 September 2025.

Draft Interpretation Statement: GST – Secondhand goods input tax deduction

On 28 July 2025, Inland Revenue issued PUB00514: GST – Secondhand goods input tax deduction. This draft interpretation statement discusses the requirements that must be met for a registered person to claim a secondhand goods input tax deduction.  This includes, among other things, a discussion of the requirement that the goods be secondhand and the meaning of secondhand.  This interpretation statement also discusses exceptions and restrictions on the amount of secondhand goods input tax deduction that can be claimed, including where the supplier and the recipient are associated persons.

Inland Revenue have also issued two fact sheets. The fact sheet GST – Meaning of secondhand supports the interpretation statement by summarising the meaning of secondhand. The fact sheet GST – Secondhand goods input tax deduction requirements – summary supports the interpretation statement by summarising the requirements.

The deadline for submissions is 10 September 2025.

Question we’ve been asked: GST listed services rules: When is a supply of listed services made through an electronic marketplace?

On 28 July 2025, Inland Revenue issued QB 25/19: GST listed services rules: When is a supply of listed services made through an electronic marketplace? The QWBA discusses one of the key requirements for when the GST listed services rules apply. That is, the supply must be made by an underlying supplier to a recipient through an electronic marketplace operator. It explains that this requirement is satisfied when the marketplace is involved in, and facilitates, supplies between underlying suppliers and recipients.

Question we’ve been asked: GST listed services rules: How do the rules apply when there is a supply of listed services and other goods or services?

On 28 July 2025, Inland Revenue issued QB 25/20: GST listed services rules: How do the rules apply when there is a supply of listed services and other goods or services? The QWBA discusses some issues with identifying the relevant supplies for the GST listed services rules. It explains what listed services are and how to apply the GST listed services rules if a supply includes listed services with other goods or services.

Inland Revenue: Change to notification preferences in myIR

On 30 July 2025, Inland Revenue announced that from 8 July 2025, they will no longer send both email and SMS notifications for alerts in myIR. If the ‘both’ option was selected, the notification preference has been updated to email only. 

Tax Information Bulletin: August 2025

On 1 August 2025, Inland Revenue issued Tax Information Bulletin Vol 37 No 7 (August 2025). It includes the following:

Operational statements

• OS 25/04: The Commissioner of Inland Revenue’s search powers
• OS 25/05: Section 17B Notices

Question we've been asked

• QB 25/17: Income tax: Can I claim a deduction for expenses I incur on repairing a recently acquired capital asset?

Case summaries

• CSUM 25/10: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime
• CSUM 25/11: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime

Technical decision summaries

• TDS 25/15: GST – input tax deductions, grants, omitted sale
• TDS 25/16: Charitable trust – transfer of assets

Technical Decision Summaries

TDS: Business restructure

On 6 June 2025, Inland Revenue issued TDS 25/14: Business restructure. It related to a restructure of a businesses (the Arrangement). The Tax Counsel Office determined the Arrangement did not result in income.

TDS: GST – input tax deductions, grants, omitted sale

On 12 June 2025, Inland Revenue issued TDS 25/15: GST – input tax deductions, grants, omitted sale. It related to input tax deductions being claimed. The Tax Counsel Office concluded that the input tax deductions claimed by the Taxpayer were not allowed.

TDS: Charitable trust – transfer of assets

On 26 June 2025, Inland Revenue issued TDS 25/16: Charitable trust – transfer of assets. It related to the trustees of a charitable trust transferring trust assets to a new trust. The Tax Counsel Office determined no income would arise from the transfer of the property.

TDS: Application of schedular payment rules

On 11 July 2025, Inland Revenue issued TDS 25/17: Application of schedular payment rules. It concerns the procurement of board directorship services by Company A from non-resident individuals through contractual arrangements with Company A’s offshore subsidiaries. It concludes that the PAYE rules did not apply to the Director Services Payments or Director Remuneration Payments under ss RD 2 and 3.

TDS: Sale of intellectual property, shares and ongoing provision of services (private ruling)

On 25 July 2025, Inland Revenue issued TDS 25/18: Sale of intellectual property, shares and ongoing provision of services. It concerned a New Zealand company marketing assets offshore through subsidiaries. An Overseas Holding company acquired the overseas assets and intellectual property, while a New Zealand subsidiary took ownership of the New Zealand based assets and provided services to the Overseas Holding Company for arm’s-length fees. The Tax Counsel Office concluded only the New Zealand Subsidiary was a NZ tax and GST resident, the sale and service fees to the overseas holding company were zero-rated for GST, the New Zealand subsidiary’s only income was the service fees, the overseas holding company had only potential dividend income from the New Zealand subsidiary, and the New Zealand subsidiary could deduct expenses related to earning service fees.

Tax cases summaries

CSUM: Lack of complete financial records secures Taxation and Charities Review Authority win for the Commissioner of Inland Revenue

On 13 December 2024, the Taxation and Charities Review Authority issued a decision in Disputant 1, Disputant 2, Disputant 3, Disputant 4, Disputant 5, Disputant 6 v The Commissioner of Inland Revenue [2024] NZTRA 004. The Commissioner’s assessments were upheld, though it was noted the Commissioner had breached the Disputants’ right to a fair trial (in a separate criminal prosecution).

CSUM: Absence of evidence makes it impossible to prove nexus with expenditure and the claimed deductions

On 16 January 2025, the Taxation and Charities Review Authority issued a decision in The Disputant v The Commissioner of Inland Revenue [2025] NZTCRA 01 (TCRA). The Disputant was a lawyer who operated his legal practice personally. The Taxation and Charities Review Authority upheld the income tax assessments by the Commissioner of Inland Revenue because the evidence failed to establish a material link between the disputed expenditure and the receipt or expectation of income.

CSUM: Taxation and Charities Review Authority rejects argument that an interest amount paid under a relationship property agreement was deductible as an expense

On 17 April 2025, Inland Revenue summarised A v Commissioner of Inland Revenue [2025] NZTCRA 02. Mr A sought to deduct interest expenses of $18,069.31 in his 2016 income tax return. This amount related to interest Mr A was required to pay his ex-wife under a relationship property agreement. The Authority held there was an insufficient nexus between the interest payments and Mr A’s assessable income and disallowed the deduction.

CSUM: Taxation and Charities Review Authority finds work to convert retail space to office space in commercial building was capital in nature

On 17 April 2025, Inland Revenue summarised P Ltd v Commissioner of Inland Revenue [2025] NZTRA 03. The Taxation and Charities Review Authority found in favour of the Commissioner of Inland Revenue, confirming assessments made in relation to the income tax years ending 31 March 2017 to 2019. The assessments disallowed deductions for construction and finishing work on a commercial property on the basis the payments were capital in nature. The Taxation and Charities Review Authority found the evidence supported the Commissioner of Inland Revenue’s position that the work was capital in nature and upheld the Commissioner of Inland Revenue’s assessments. The work involved seismic strengthening and adding a new glass façade to modernise the building’s appearance.

CSUM: Taxation and Charities Review Authority finds remediation work on unit was capital in nature

On 22 April 2025, Inland Revenue summarised P v Commissioner of Inland Revenue [2025] NZTRA 04. The Taxation and Charities Review Authority confirmed the Commissioner of Inland Revenue’s assessments for the income tax years ending 31 March 2015 and 2017 disallowing deductions claimed for remedial work undertaken on the disputant’s unit. The remedial work to fix weathertightness issues changed the character of the asset and was capital in nature.

CSUM: High Court dismisses judicial review of deductions to decline proposals for relief under s 177 of the TAA

On 30 June 2025, Inland Revenue issued a summary of Anthony v Commissioner of Inland Revenue [2025] NZHC 1382. At issue is the interpretation of provisions of the Tax Administration Act 1994 and the Commissioner of Inland Revenue’s obligation to collect the highest net revenue that is practicable within the law. The Court found it has broad discretion in deciding whether to accept relief proposals and must balance considerations of maximising recovery from individual taxpayers with broader public interest considerations including, importantly, the integrity of the tax system.

CSUM: Risk of double recovery due to potential enforcement action by Inland Revenue does not prevent profit forfeiture orders under proceeds of crime regime

On 30 June 2025, Inland Revenue issued a summary of Commissioner of Police v Masonic Limited and others [2025] NZCA 205. The Court of Appeal granted the Commissioner of Police’s appeal, agreeing with the Commissioner of Police and Commissioner of Inland Revenue that where tax has been evaded and not subsequently paid to the Commissioner of Inland Revenue, the tax evader has benefited from significant criminal activity, and a profit forfeiture order should be made. The court rejected the view that the Commissioner of Inland Revenue’s ability to recover unpaid tax means there can be no benefit to the offender.

US: A closer look: Inside the new tax law

Deloitte US have published analysis of the One Big Beautiful Bill Act. A closer look: Inside the new tax law offers a detailed discussion of the Act and makes observations on key provisions. The appendix includes a series of side-by-side comparisons showing how the Act’s provisions align with those in the House and Senate bills and with the tax law as in effect—generally in 2025— depending on the effective date of the relevant provision.

European VAT Refund Guide 2025

The European VAT refund guide has been updated. It summarises the rules and procedures to obtain a VAT refund in 32 European countries.

Tax Transparency in Asia 2025

On 26 May 2025, the OECD Global Forum on Transparency and Exchange of Information for Tax purposes published Tax Transparency in Asia 2025.

Consolidated text of the Common Reporting Standard (2025)

On 2 June 2025, the OECD published an official consolidated text of the Common Report Standard, incorporating the amendments made, resulting from the comprehensive review of the Standard.

Peru deposits its instrument of ratification of the Multilateral BEPS Convention

On 11 June 2025, the OCD announced that Peru has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). As of June, 89 jurisdictions have either ratified, accepted, or approved the BEPS Convention resulting in the modification of over 1600 treaties. Around 400 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.

Mobilising domestic resources in low- and middle-income countries

On 11 June 2025, the OECD published a working paper applying the Domestic Resource Mobilisation Framework to social protection financing. The Framework identifies country-specific tax policy measures and estimates their tax revenue potential to mobilise additional domestic resources in low- and middle-income countries.

Antigua and Barbuda signs the Multilateral BEPS Convention

On 18 June 2025, the OECD announced that Antigua and Barbuda signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. It becomes the 105^th jurisdiction to sign the BEPS Convention.

36 new peer review results released

On 26 June 2025, the OECD released 36 new peer review results under BEPS Action 14 on Mutual Agreement Procedures (MAP).

Intergovernmental fiscal transfers and fiscal equalisation in a time of consolidation

On 30 June 2025, the OECD published a work paper examining how selected countries adapt their fiscal equalisation systems under fiscal pressures, identifying design features that preserve inter-regional fairness while maintaining efficiency.

Tax Transparency in Africa 2025: Africa Initiative Progress Report

On 1 July 2025, the OECD issued Tax Transparency in Africa 2025.

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 South Africa, July 2025)

On 17 July 2025, the OECD published the Secretary-General’s tax report setting 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 Two-Pillar Solution, and tax transparency, as well as updates regarding the April Inclusive Framework Plenary meeting and initiatives to find simplification and reduce compliance burdens. 

Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes

On 17 July 2025, the OECD published its report to G20 Finance Ministers and Central Bank Governors taking stock on transparency and exchange of information for tax purposes since the inception of the G20.

Report on the work of the Inclusive Forum on Carbon Mitigation Approaches

On 17 July 2025, the OECD published a report from the Secretary-General to G20 Finance Ministers and Central Bank Governors presenting the latest developments with the Inclusive Forum on Carbon Mitigation Approaches (IFCMA).

Global Forum releases latest batch of peer reviews on transparency and exchange of information

On 21 July 2025, the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) published five new peer review reports on transparency and exchange of information on request (EOIR). The reports for Honduras, Madagascar, Mongolia, Oman, and Trinidad and Tobago were approved by the Global Forum’s dedicated Peer Review and Monitoring Group in June 2025 and subsequently adopted by the Global Forum members.

OECD publishes second batch of updated transfer pricing country profiles with new insights on hard-to-value intangibles and simplified distribution rules

On 22 July 2025, the OECD announced the release of a new batch of updated transfer pricing country profiles, including New Zealand.

The transfer pricing country profiles focus on the key transfer pricing aspects of each country domestic tax legislation including: the arm's length principle; methods, comparability analysis; intangible property; intra-group services; cost contribution agreements; documentation; administrative approaches to avoiding and resolving disputes; safe harbours and other implementation measures.

OECD publishes data exchange formations for Pillar Two and CARF, issued updated FAQs

On 30 July 2025, the OECD published two XML Schemas and associated User Guides to support the reporting and exchange of information under the Global Minimum Tax (GMT) and the Crypto-Asset Reporting Framework (CARF).

• The GloBE Information Return (Pillar Two) Status Message XML Schema allows Competent Authorities that have received information through the GloBE Information Return (GIR) XML Schema to report back to the sending Competent Authority whether the information was provided in line with the agreed GIR validation rules. These rules, aimed at ensuring quality GIR data, are set out in detail in this document.
• The updated version of the Crypto-Asset Reporting Framework (CARF) XML Schema supports the automatic exchange of information pursuant to the CARF, as approved by the OECD in 2023 and contains a number of technical adjustments on the CARF XML Schema approved in 2024.

The OECD has also issued a new set of frequently asked questions (FAQs) to provide interpretative guidance on the CARF and the amended Common Reporting Standard. These FAQs help to ensure consistency in the implementation of both standards.

Zimbabwe signs Multilateral Convention to tackle tax evasion and avoidance

On 31 July 2025, the OECD announced Zimbabwe has signed the Multilateral Convention to tackle tax evasion and avoidance, bringing the total number of participating jurisdictions to 151.

Ring-Fencing Mining Income

On 31 July 2025, the OECD published a practice note aiming to clarify what ring-fencing means in the context of mining taxation, the advantages of adopting ring-fencing rules, and how to mitigate potential challenges through robust tax policy design and effective tax administration practices. It describes and evaluates the different options for designing ring-fencing rules based on the experience of resource-rich countries and highlights key implementation issues that have emerged. This practice note will help governments of resource-rich countries decide if ring-fencing rules are necessary and, if they are, how to design them to safeguard the timing of government revenues. Each resource-rich country will have to consider, prior to implementation, the appropriateness, including the positive and negative aspects of a ring-fencing regime as a policy option given their fiscal conditions and taxation framework.

Inventory of Tax Technology Initiatives

The OECD has published the Inventory of Tax Technology Initiatives, which contains information on technology tools and digitalisation solutions implemented by more than 100 national tax administrations.

Tax Administration 3.0: From Vision to Strategy

The OECD has published a report on Tax Administration 3.0.

Recognising progress and reducing burdens in the BEPS minimum standards

The OECD has published a document presenting recommendations endorsed by Inclusive Framework at the April 2025 plenary meeting and includes, as an annex, the revised peer review methodology for the Forum on Harmful Tax Practices' work on BEPS Action 5, approved during that meeting.