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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

RA 26/01 Failure to pay PAYE deductions to Inland Revenue

16 Mar 2026 Revenue alerts / 2026

The Commissioner is issuing this Revenue Alert to highlight the criminal penalties that may apply where employers do not pass PAYE and other amounts deducted from an employee’s salary or wages to Inland Revenue by the due date.  Making deductions and failing to pay them to Inland Revenue is a serious offence carrying a maximum sentence of up to 5 years in prison.  This Revenue Alert highlights that the Commissioner will consider, where appropriate, the possibility of prosecution action where this behaviour is identified. 

TDS 26/02 Discretionary Investment Management Service fees

16 Mar 2026 Technical decision summary / 2026
This item summarises a private ruling about whether the single global fee charged by a Discretionary Investment Management Services provider is an exempt supply of financial services under s 14 of the Goods and Services Tax Act 1985.

CFC 2026/05 Non-attributing active insurance CFC status TOWER Limited

05 Mar 2026 Determinations / International tax / CFCs / 2026

This determination provides that National Pacific Insurance (Tonga) Limited is a non-attributing active CFC under s EX 21B of the Income Tax Act 2007.  This means a person will have no attributed CFC income or loss from the company under sections CQ 2 and DN 2 of the Act.  This determination applies for the 2026 and 2027 income years.

CFC 2026/04 Non-attributing active insurance CFC status TOWER Limited

05 Mar 2026 Determinations / International tax / CFCs / 2026
This determination provides that National Pacific Insurance Limited is a non-attributing active CFC under s EX 21B of the Income Tax Act 2007.  This means a person will have no attributed CFC income or loss from the company under sections CQ 2 and DN 2 of the Act.  This determination applies for the 2026 and 2027 income years.

CFC 2026/03 Non-attributing active insurance CFC status TOWER Limited

05 Mar 2026 Determinations / International tax / CFCs / 2026
This determination provides that National Insurance Company (Holdings) Limited, Tower Insurance (Fiji) Limited and Southern Pacific Insurance Company (Fiji) Limited are non-attributing active CFCs under s EX 21B of the Income Tax Act 2007.  This means a person will have no attributed CFC income or loss from the company under sections CQ 2 and DN 2 of the Act.  This determination applies for the 2026 and 2027 income years.

CFC 2026/02 Non-attributing active insurance CFC status (Tower Limited)

05 Mar 2026 Determinations / International tax / CFCs / 2026
This determination provides that National Pacific Insurance (Cook Islands) Limited is a non-attributing active CFC under s EX 21B of the Income Tax Act 2007.  This means a person will have no attributed CFC income or loss from the company under sections CQ 2 and DN 2 of the Act.  This determination applies for the 2026 and 2027 income years.

CFC 2026/01 Non-attributing active insurance CFC status TOWER Limited

05 Mar 2026 Determinations / International tax / CFCs / 2026

This determination provides that National Pacific Insurance (American Samoa) Limited is a non-attributing active CFC under s EX 21B of the Income Tax Act 2007.  This means a person will have no attributed CFC income or loss from the company under sections CQ 2 and DN 2 of the Act.  This determination applies for the 2026 and 2027 income years.


FDR 2026/01 No FDR method - Daintree High Income Trust – NZD class units

04 Mar 2026 Determinations / International tax / Foreign investment funds / 2026
This determination provides that a New Zealand resident investor cannot use the fair dividend rate method to calculate FIF income from an investment in Daintree High Income Trust - NZD class units.

Volume 38 No 2 Tax Information Bulletin - March 2026

03 Mar 2026 TIB / Volume 38 - 2026

Determinations

  • PROV28: Provisional depreciation rate for battery energy storage systems (modular)
  • DET 26/01: Declaration that the January 2026 severe weather event is an emergency event for the purposed of family scheme income
  • DET 26/02: Declaration that the February 2026 severe weather event is an emergency event for the purposed of family scheme income
  • NSC 2026: National Stand Costs for Specified Livestock Determination 2026

Product rulings

  • BR Prd 25/07: New Zealand Bloodstock Finance and Leasing Limited
  • BR Prd 25/08: Northride New Zealand Limited

Technical decision summary

  • TDS 26/01: Opening value of FIF income calculation

IS 26/01 Income tax – deductibility of repairs and maintenance expenditure – general principles

02 Mar 2026 Interpretation statements / 2026
This interpretation statement considers the general principles governing the income tax treatment of expenditure taxpayers incur in carrying out work on tangible property they use in a business or income-earning activity.

Public guidance work programme

If you have any tax technical or interpretative issues you believe should be addressed, please share your suggestions by 2 April 2026. Your input is invaluable in shaping the guidance that will be published.

Send your suggestions to [email protected] or complete the form on the Tax Technical website.

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Consultations closing soon

ED0267: Returns of capital: Off-market share cancellations – bright line tests and the Commissioner’s notice requirements and other matters

Consultation closes:  23 March 2026