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This site contains the Commissioner’s interpretation of tax law, our Work Programme for the year, and where you can provide feedback on any new work underway or apply for a binding tax interpretation. Publications on this Tax Technical website are correct at the date of issue. Read more
This site contains the Commissioner’s interpretation of tax law. Read more

Volume 37 No 11 Tax Information Bulletin - December 2025

01 Dec 2025 TIB / Volume 37 - 2025

Determination

  • FDR 2025/06: Determination the fair dividend rate method may not be used to calculate FIF income by investors in the Nuveen Global Sustainable Bond Fund – Class X NZD Distributing (H) share class

Binding Rulings

  • BR Prd 25/05: Ministry of Education
  • BR Prd 25/06: Ministry of Education

Interpretation statements

  • IS 25/22: GST – Secondhand goods input tax deduction 
  • IS 25/23: GST – Meaning of payment
  • IS 25/24: Income tax and GST – industries other than forestry registered in the Emissions Trading Scheme
  • IS 25/25: Income tax – business activity

Question we’ve been asked

  • QB 25/21: Income tax – Public private partnership projects and business continuity test for losses

Technical decision summaries

  • TDS 25/24: The supply of accommodation in a serviced apartment
  • TDS 25/25: Restructure and transfer of shares
  • TDS 25/26: How does the business continuity test apply to a consolidated group?

IS 25/25 Income tax – business activity

13 Nov 2025 Interpretation statements / 2025

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 s CB 1 and to other provisions in the Income Tax Act 2007 where carrying on a business is a requirement.

Tax Information Bulletin - Vol 37 No 11, December 2025

FDR 2025/06 Determination the fair dividend rate method may not be used to calculate FIF income by investors in the Nuveen Global Sustainable Bond Fund – Class X NZD Distributing (H) share class

11 Nov 2025 Determinations / International tax / Foreign investment funds / 2025

Subject to the conditions recorded below, any investment by a New Zealand resident investor in the Class X NZD Distributing Hedge share class of the Nuveen Global Sustainable Bond Fund, (ISIN IE000RJY9QW0) a sub-fund of Nuveen Global Investors Fund Public Limited Company (“Nuveen GIF”), to which none of the exemptions in sections 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 fair dividend rate ("FDR") method to calculate foreign investment fund income for the interest.

 

Tax Information Bulletin - Vol 37 No 11, December 2025

IS 25/23 GST – Meaning of payment

11 Nov 2025 Interpretation statements / 2025

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.

Tax Information Bulletin - Vol 37 No 11, December 2025

IS 25/24 Income tax and GST – industries other than forestry registered in the Emissions Trading Scheme

11 Nov 2025 Interpretation statements / 2025

This interpretation statement applies to industries registered in the Emissions Trading Scheme, other than forestry which is taxed differently. The industries include those that are emissions intensive and trade exposed, as well as those involved in removal activities and some horticultural activities. The statement sets out the conceptual framework for the income tax treatment of emission liabilities and emissions units (NZUs) in these sectors. It then explains how to calculate deductions for emission liabilities and it discusses the treatment of NZUs as income. Finally, there is a brief discussion of the GST treatment of NZUs.
For a discussion on forestry activities registered in the ETS see: IS 25/13: Income Tax and GST – forestry activities registered in the Emissions Trading Scheme.

Tax Information Bulletin - Vol 37 No 11, December 2025

IS 25/22 GST – Secondhand goods input tax deduction

11 Nov 2025 Interpretation statements / 2025

This 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.

Tax Information Bulletin - Vol 37 No 11, December 2025

IS 25/22 FS 3 GST – secondhand goods input tax deduction – associated person limitation - fact sheet

11 Nov 2025 Fact sheets / 2025

This fact sheet accompanies IS 25/22: GST – Secondhand goods input tax deduction, which discusses the requirements that must be met for a registered person to claim a secondhand goods input tax deduction.  The amount that a person can claim as a secondhand goods input tax deduction may be limited if the goods are acquired from an associated person.  This fact sheet summarises this limitation. 

IS 25/22 FS 2 GST – Secondhand goods input tax deduction requirements – summary - fact sheet

11 Nov 2025 Fact sheets / 2025
This fact sheet accompanies IS 25/22: GST – Secondhand goods input tax deduction, which discusses the requirements that must be met for a registered person to claim a secondhand goods input tax deduction. This fact sheet is a summary of those requirements.

IS 25/22 FS 1 GST – Meaning of secondhand - fact sheet

11 Nov 2025 Fact sheets / 2025

This fact sheet accompanies IS 25/22: GST – Secondhand goods input tax deduction, which discusses the requirements that must be met for a registered person to claim a secondhand goods input tax deduction.  One of the requirements is that the goods supplied are secondhand.

IS 25/23 GST – Meaning of payment

10 Nov 2025 Interpretation statements / 2025
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.

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