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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 3 TIB - April 2025

01 Apr 2025 TIB / Volume 37 - 2025

Determinations

  • NSC 2025: National Standard Costs for Specified Livestock Determination 2025 
  • ITR36: 2025 International tax disclosure exemption

Interpretation statement

  • IS 25/04: What an employee share scheme is, the taxing date and apportionment 

Technical decision summary

  • TDS 25/02: Financing arrangement to fund the refurbishment of a capital asset
  • TDS 25/03: GST – Output tax deductions, shortfall penalties
  • TDS 25/04: Deductions and shortfall penalties
  • TDS 25/05: GST - input tax, taxable
  • TDS 25/06: Receipt of funding

ITR36 2025 International tax disclosure exemption

31 Mar 2025 Determinations / International tax / Disclosure exemptions / 2025

Determination setting out the 2025 international tax disclosure exemption.

Tax Information Bulletin - Vol 37 No 3, April 2025

BR Prd 25/01 Taxi Limited

31 Mar 2025 Rulings / Product / 2025

This Arrangement is the lending of amounts by Taxi Limited to its clients secured by the client transferring by way of security their entitlement to amounts deposited in the tax pooling account operated by Tax Traders Limited.

This Ruling:

  • relates to the imputation credit treatment of the transfer of tax credits under the Arrangement; and
  • applies to clients that are an “ICA company” (as defined in s YA 1 of the Income Tax Act 2007).

IS 25/06 Employer obligations for employee share scheme benefits paid in cash

31 Mar 2025 Interpretation statements / 2025

This interpretation statement explains an employer’s PAYE, student loan and KiwiSaver obligations when an employee receives a benefit under an employee share scheme that is paid in cash. 

It updates and replaces IS 24/05 to reflect changes in the Taxation (Annual Rates for 2024-25, Emergency Response, and Remedial Measures) Act 2025 that mean ACC earners’ levy does not apply to cash-settled ESS benefits.  This aligns the treatment of cash-settled and share-settled ESS benefits. 

IS 25/07 PAYE – How an employer funds the tax cost on an employee share scheme benefit

31 Mar 2025 Interpretation statements / 2025

This interpretation statement explains an employer’s withholding and reporting obligations related to PAYE, student loans and KiwiSaver if an employer wants to fund the cost of tax (and student loan, if applicable) on an employee share scheme benefit provided in shares. 

It updates and replaces IS 24/06 to reflect changes in the Taxation (Annual Rates for 2024-25, Emergency Response, and Remedial Measures) Act 2025 that mean ACC earners’ levy does not apply to cash-settled ESS benefits.  This aligns the treatment of cash-settled and share-settled ESS benefits.   

IS 25/06 FS Employer obligations for employee share scheme benefits paid in cash - fact sheet

31 Mar 2025 Fact sheets / 2025

This fact sheet accompanies interpretation statement IS 25/06: Employer obligations for employee share scheme benefits paid in cash, which explains an employer’s PAYE, student loan and KiwiSaver obligations when an employee receives a benefit under an employee share scheme that is paid in cash.  It updates and replaces IS 24/05 FS to reflect changes in the Taxation (Annual Rates for 2024-25, Emergency Response, and Remedial Measures) Act 2025 that mean ACC earners’ levy does not apply to cash-settled ESS benefits.  This aligns the treatment of cash-settled and share-settled ESS benefits.      

OS 25/02 Valuation of livestock

31 Mar 2025 Operational statements / 2025
This statement describes the options available for taxpayers who are in the business of farming to value the livestock they have on hand at balance date.  The statement also contains commentary on changes made to section EC 1 of the Income Tax Act 2007 by the Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025.

OP 25/01 Commissioner’s operational position on the GST treatment of fees paid in relation to managed funds

31 Mar 2025 Operational positions / 2025
IS 25/05 sets out the security the Commissioner’s view on the GST treatment of fees received by a manager of a managed fund and fees received by third-party suppliers (including investment managers) for supplies made to the manager of a managed fund. This interpretation statement was issued on 31 March 2025.

The Commissioner recognises that immediate implementation of the position outlined in this interpretation statement could be difficult for some taxpayers, due to required changes to, for example, computer systems and/or contractual arrangements.

Therefore, the Commissioner will not be devoting resources to determining whether a taxpayer has applied the interpretation statement in GST periods that cover 1 April 2025 to 31 March 2026.

However, the Commissioner expects taxpayers to have adopted the position outlined in IS 25/05 by 1 April 2026.

IS 25/05 GST treatment of fees paid in relation to managed funds

31 Mar 2025 Interpretation statements / 2025
This interpretation statement considers the GST treatment of fees received by a manager of a managed fund and fees received by third-party suppliers (including investment managers) for supplies made to the manager of a managed fund.

FDR 2025/04 Determination the fair dividend rate method may not be used to calculate FIF income by investors in Institutional Cash Series plc: BlackRock ICS US Treasury Fund – Premier (Dis) Shares

26 Mar 2025 Determinations / International tax / Foreign investment funds / 2025
Any investment by a New Zealand resident investor in the Premier (Distributing) share class of the Blackrock ICS US Treasury Fund, a sub-fund of Institutional Cash Series plc, 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.

Consultations closing soon 

PUB00476: GST - taxable activity

Closes on 4 April 2025

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