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Tax Alert - February 2013


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Tax AlertTax Alert is a monthly publication that keeps you up to date with the latest developments in tax. The alert is compiled by our national tax specialists who are continually monitoring the outlook for new tax developments and analysing the implications for our clients.

Fundamental changes proposed to thin capitalisation rules

In a brief issues paper innocuously entitled “Review of the thin capitalisation rules”, Inland Revenue policy officials and the Treasury have started 2013 with gusto, proposing significant changes to New Zealand’s thin capitalisation rules.

The changes, if enacted, will extend the ambit of the rules so that they operate as officials consider they were intended to. Although there is a particular focus on private equity investment vehicles, certain aspects of the proposed changes, if implemented, are likely to introduce material uncertainty and potential overreach into the rules. Those currently subject to the thin capitalisation rules may also face increased compliance costs resulting from some of the changes.

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