An updated Double Tax Agreement (DTA) between Canada and New Zealand came into force on 26 June 2015. The new agreement will generally lower withholding tax (WHT) on dividends, interest and royalties between the two countries and has been welcomed by investors in both countries. The changes will begin to take effect from 1 August 2015.
Pearse Trust Blog
Further to our previous overview and summary blogs, The Small Business, Enterprise and Employment Act (the Act) received Royal Assent and was passed into law in the UK on 26 March, 2015. This blog contains an update on certain corporate related aspects of the Act.
New Zealand’s Budget 2015 announced by Minister of Finance, Hon Bill English on 21 May 2015, is being called “a plan that’s working”. The budget highlighted a positive outlook for the economy and included a range of tax-related measures and investment initiatives.Some of these initiatives are aimed at New Zealand businesses and are being referred to as the “Business Growth Agenda”.
As discussed in a previous blog post, New Zealand is a popular jurisdiction for settlement or re-domiciliation of a Trust. This is because, when structured correctly, the New Zealand Foreign Trust will not be subject to taxation.
In order to avail of optimum tax benefits, a New Zealand resident trustee referred to as a 'resident foreign trustee’ must be appointed. The resident foreign trustee is typically a New Zealand corporate trustee. Foreign-sourced income derived by a New Zealand resident trustee is exempt from income tax in New Zealand provided the settlor is not resident in New Zealand.Read More
This blog will examine the tax considerations in relation to loans to participators. This anti avoidance measure attacks the practice of withdrawing profits from close companies in the form of loans. Without this measure it would be possible for shareholders in close company to borrow money from the company instead of taking remuneration or dividends.
Today we are going to examine the New Zealand Limited Partnership (LP) and the New Zealand Look Through Company (LTC), both of which are particularly distinguished due to their flow through tax status.
1. New Zealand Limited Partnership
The New Zealand LP is a partnership structure similar to those established in overseas jurisdictions and can be used for a variety of purposes such as holding and trading assets worldwide. They enjoy separate legal ownership from their owners, who are referred to as partners.Read More
The Irish Government has courted international controversy with its proposal for a preferential tax regime for income derived from intellectual property, known as the Knowledge Development Box (“KDB”). This blog post will discuss the outline of the proposal.
The proposed KDB is in line with the commitment contained in the Road Map for Ireland’s Tax Competitiveness, which was published in October 2014 alongside the Irish Government’s Budget for 2015. It was noted in the document that the global economy is evolving and business assets resulting from investment in “knowledge-based capital”, such as intellectual property, are becoming a significant driver of economic growth in OECD economies.Read More
The New Zealand Look-Through Company is an ideal alternative to a limited partnership structure, such as the New Zealand Limited Partnership, for clients who are looking for a fiscally transparent corporate entity, but prefer the familiarity of a limited liability company.
The Look-Through Company provides investors with the option of benefiting from partnership-style transparent tax treatment by electing to become an LTC, subject to approval by the Inland Revenue Department of New Zealand.Read More
Following on from our previous blog Changes for New Zealand Companies –Companies Amendment Act 2014, the Companies Office have released their timeline for implementation of the new rules. The important changes will be phased in throughout 2015 and the prescribed timeline should give all companies sufficient time to prepare to meet their new compliance obligations.
Companies Amendment Act 2014The new rules are aimed at preventing the misuse of New Zealand companies by enhancing the powers of the Registrar and improving the quality of information by the Registrar. This will include a new requirement to have at least one resident director and additional disclosure by companies in respect of their ultimate ownership. Read More
Can the body of international tax rules, which have developed in such an unruly and illogical fashion since the early 20th century, really be transformed into a coherent whole within the space of a few years? The Organisation of Economic Development and Cooperation (“OECD”) seems to think so. Recent developments however, suggest that the OECD may have bitten off more than it can chew with its BEPS project. Read More