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Snapshot of recent developments

Tax Alert - November 2023

Tax legislation and policy announcements

Changes to charity regulations affecting all charities in New Zealand

The main provisions of the Charities Amendment Act 2023 came into force on 5 October 2023, and will affect all New Zealand charities. The Charities Amendment Act 2023: What Charities Need To Know booklet and website Charities reform — Seed The Change | He Kākano Hāpai provide information on the changes.

Information release: Deductibility of co-operative company dividends

On 17 October 2023, Inland Revenue published an information release in relation to the deductibility of co-operative company dividends (relating to Fonterra). The release includes the cabinet paper and minute seeking agreement on the Supplementary Order Paper that introduced the amendment.

Inland Revenue statements and guidance

Tax Information Bulletin Vol 35 No 9 October 2023

On 2 October 2023, Inland Revenue published the Tax Information Bulletin for October 2023.

Global tax news

New Zealand and Slovakia sign tax treaty

On 26 September 2023, officials from Slovakia and New Zealand signed an income tax treaty which broadens the base of bilateral agreements, respects current international requirements in the fight against tax evasion and profit shifting, and increases transparency.

Austrian National Council approves Protocol to Tax Treaty with New Zealand

On 18 October 2023, the Austrian National Council approved the amending protocol, signed on 12 September 2023, to the Austria - New Zealand Income and Capital Tax Treaty (2006). The protocol is aimed at, among other things, avoiding abuse of agreements in the case of dual-domiciled companies.

Netherlands and New Zealand sign Memorandum of Arrangement on Implementing MLI Arbitration Process under Tax Treaty

On 15 August 2023 and 18 September 2023, respectively, the Netherlands and New Zealand signed a Memorandum of Arrangement to establish the mode of application of the arbitration process provided for in Part VI (Arbitration) of the OECD MLI. The Competent Authorities may modify or supplement this memorandum by an exchange of letters.

OECD updates

Progress continues in strengthening Country-by-Country reporting

On 25 September 2023, the OECD released the outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large multinational enterprises.

BEPS Convention updates

On 27 September, the OECD announced that Eswatini signed the BEPS Convention, and Serbia deposited a notification to extend the application of the Convention on its existing treaties. Armenia and Côte d'Ivoire have deposited their instruments of ratification for the Convention, which will enter into force on 1 January 2024 for both countries.

Report: Tax Administration 2023

On 29 September 2023, the OECD released Tax Administration 2023. The report surveyed 58 economies with net revenue of EUR 13.4 trillion and more than 900 million taxpayers, highlighting the scale, complexity, and digital transformation journeys of tax administrations worldwide.

Multilateral Convention to Facilitate Implementation of Pillar Two Subject to Tax Rule

On 3 October 2023, the OECD announced that the Inclusive Framework on BEPS has concluded negotiations on a multilateral instrument (MLI) to implement the Subject to Tax Rule (Rule).

The Rule will enable developing countries to tax certain intra-group payments, in instances where these payments are subject to a nominal corporate income tax rate below 9%. The MLI will allow countries to implement the STTR in existing bilateral tax treaties.

Multilateral Convention to address globalisation and digitalisation

On 11 October 2023, the OECD announced that the Inclusive Framework on BEPS has released the text of the new Multilateral Convention to Implement Amount A of Pillar One which updates the international tax framework to co-ordinate a reallocation of taxing rights to market jurisdictions, improve tax certainty, and remove digital service taxes.

Report: Methodological Guidelines for Environmentally Related Tax Revenue Accounts

On 12 October 2023, the OECD released a report presenting the methodological guidelines for compiling Environmentally Related Tax Revenue accounts, in line with the System of Environmental Economic Accounting.

OECD webinar recordings

On 16 October, the OECD hosted its latest Tax Talks webinar, which presented an update on the OECD’s work. The recording and presentation are available here.

On 27 October, the OECD hosted a webinar on the key features of the MLC, including applying Amount A rules, the tax certainty framework for Amount A, and the removal and standstill of digital services taxes and relevant similar measures. The recording is available here.

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

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