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Edition 2, March 2016
With the tax year-end approaching, it’s timeto take stock of your tax affairs. Considerour year-end tax tips.
Inland Revenue has access to moreinformation than ever before. It is startingto transform how it does business. MichaelWoodhouse, the new Revenue Minister, setout his thoughts on that work in his speechto the International Fiscal Association’s NewZealand conference. He stressed twoaspects of transformation: the need forInland Revenue to boost tax compliance andhis desire to reduce business compliancecosts.
At present, we’re seeing more action aroundboosting compliance than on cost reduction.We highlight three issues that show howincreasing transparency over tax matterswill affect New Zealand business:
► Inland Revenue’s proposals to accessthird party datasets and remotelystored information
► The Privacy Commissioner’sTransparency Reporting trial showing
the extent to which Inland Revenueuses its current powers
► Upcoming implementation of AutomaticExchange of Information between taxauthorities worldwide
Like New Zealand, Australia is moving toapply GST to cross border supplies of digitalproducts and other imported services. Weexplain the implications for New Zealandbusiness.
Parliament’s spent the last year consideringa new research and development (R&D) losstax credit. At long last, the measures beenenacted, backed to 1 April 2015.
Finally, Tax Watch in Brief rounds out otherrecent developments.
Welcome to TaxWatchYear-end tax tips in achanging world
Tax Watch, Edition 2, March 2016 EY | 2
Geoff BlaikieHead of TaxTel: +64 4 495 [email protected]
Aaron QuintalPartner - TaxTel: +64 9 300 [email protected]
David SnellTax Watch EditorExecutive Director - TaxTel: +64 4 470 [email protected]
Tax Watch, Edition 2, March 2016 EY | 3
Year-end tax planning
Review your overall approach to tax
The end of the financial year is fast approaching, with 31 Marchjust around the corner.
We’re experiencing a climate of tax change, with businessescontinuing to focus on tax issues. Now’s the time both toconsider perennial year-end issues and to review your overalltax approach.
Significant tax reforms
Change appears to be the new norm. Ask yourself thesequestions:
► Which 2015/2016 tax law changes will affect you?
► Which forthcoming issues do you need to plan for?
► What are your main tax exposures?
► Why the tax paid as shown in your company’s financialreports does not equate 28% of accounting profit?
Large businesses will also want to consider:
► Does your board understand your tax profile, risks, andconsequences?
► Is your tax function well-integrated with the business?
► Does the trend towards greater information exchangebetween revenue authorities affect your business?
Which changes will affect you?
January’s Tax Watch summarized the reforms we expect to seein 2016 along with the key developments in 2015. Use thischecklist to determine which developments could affect you:
Issues Priority
Indirect tax
2015 GST on online services
Proposals on capital raising costs, zero-ratingrules, apportionment methodologies
2016 Changes to de minimis threshold
GST-focussed reviews and audits
Customs and Excise Act review
Private business
2015 Two-year bright line test
Debt remission between related parties
Financial reporting changes
2016 Continuation of Inland Revenue’s businesstransformation
Reform of trusts
International tax
2016 Local implementation of OECD base erosionand profit shifting (BEPS) recommendations
Related party lending and withholding taxes
Impact of Australian reforms
Transfer pricing
2015 New international questionnaire
Impact of Australian reforms
2016 Continued scrutiny of cross-border financialarrangements
Transfer pricing documentation expectations
Opportunity to set advance pricingagreement
Tax controversy
2016 Impact of OECD BEPS recommendations
Reduction of tax secrecy
Increased tax avoidance litigation
Reconsideration of Commissioner’s discretionto reassess
Compliance with existing law
Make sure you’re getting the best result under existing law.Consider:
Tax Watch, Edition 2, March 2016 EY | 4
Complete your tax provisionwith balances for current tax,deferred tax, and tax expense,and make sure you havesupporting informationavailable.
Existing law Considerations
Timing of income anddeductions
Financial reporting, tradingstock, and depreciation rules;bad debts, repairs,maintenance, and researchand development (R&D) costs
Equity management,especially imputation
Make sure your imputationcredit account is not in debtat 31 March; consider optionsregarding imputing dividends,paying tax on account andgrouping
Debt financing – maximiseinterest deductions
Thin capitalisation position,possible alternativetreatments under financialarrangement rules; debtforgiveness
Impact of acquisitions,disposals, or changes inbusiness
Carry forward of losses andimputation credits; taxgrouping choices; intragrouptransactions
International issues Tax residence of individualsand businesses
Take into account any special rules that may apply to you – forexample, special rules may apply to farming, forestry,aquaculture, charities and not-for-profits, co-operatives, andmineral and petroleum miners. Can you claim the new cashcredit for research and development tax losses for the yearending 31 March 2016?
Prepare for upcoming financial statement reviews
With financial statements preparation in train, act now to ensureyou have everything ready for the auditors.
Complete your tax provision with balances for current tax,deferred tax, and tax expense, and make sure you havesupporting information available:
Supporting information ü
Trial balance
Tax calculation
Current and deferred tax proof
Tax expense reconciliation
Latest income tax return filed with Inland Revenue
Prior year financial statements
Loss letters and Inland Revenue look-ups showingoutstanding tax balances
Tax intermediary account statements
Tax fixed asset register
Supporting workpapers for tax adjustments
Any specific tax advice received supporting the taxposition taken
An outline of any significant or unusual transactions
Information concerning any Inland Revenue audits,reviews or other requests
We’re keen to work through all these issues with you. Talk to us.
Andrea Catte,New Zealand Leader,Global Compliance and Reporting,[email protected],Tel: +64 21 933 576
Angela Williams,Executive Director, Tax Policy,[email protected],Tel: +64 3 379 1870
Tax Watch, Edition 2, March 2016 EY | 5
Information is power
The discussion document doesnot explain how the twoproposals would be administered.It also neglects to address theadditional compliance costs thatwould be borne by taxpayers.
Inland Revenue proposes greateraccess to taxpayer information
Inland Revenue is taking steps to ensurethat technological change does notobstruct its continued access to as muchtaxpayer information as possible.
In November 2015, the governmentreleased Making Tax Simpler –Towards aNew Tax Administration Act.
While most topics covered wereadministrative, Inland Revenue proposedtwo extensions to the Commissioner’sinformation gathering powers:
1. Allow Inland Revenue to repeatedlyaccess third party datasets,presumably as a matter of routinepractice to support its normal auditfunctions.
2. Compel taxpayers to provide accessto remotely stored information, suchas information stored in the cloud.Inland Revenue has found itincreasingly difficult to use itspowers to obtain information fromtaxpayer’s computers when theactual information it seeks is not onthat device. The proposed extensionwould alleviate this access issue.
Why are these new powersrequired?
Disappointingly, the government hasfailed to explain why these new powersare required. While Inland Revenue’s needto access relevant taxpayer information islegitimate, its information gatheringpowers are already broader and moreflexible than other government agencies.
Courts have repeatedly held that InlandRevenue can use its existing powers togather general information from thirdparties to conduct “fishing expeditions”with the hope of discovering information.
In addition, a survey conducted by thePrivacy Commissioner found that InlandRevenue made 4670 informationrequests over a three month period to tenlarge corporations (from the financialservices, communications, and utilitiessectors). This was the most requests byany government agency, and illustratesInland Revenue’s use of its existingpowers.
Lack of detail
1. Access to third party datasets
The discussion document fails to address:
► Whether all taxpayers within acertain category, or only those withthe most data, would be required toprovide third-party datasets. Anydisparity could create disadvantagesbetween competitors.
► Whether third party datasets mustbe provided in their raw form, or iftaxpayers would be required tocollate the datasets before providingthem to Inland Revenue. Requiringcollation would impose additionalcompliance costs.
► Whether the obligation applies onlyto third-party datasets collected byNew Zealand taxpayers. If it appliesto all third-parties, how will thatobligation be enforced against non-residents with no physical presencein New Zealand? If the obligationonly applies to New Zealandtaxpayers, they will face acompetitive disadvantage andincreased compliance costscompared with their overseascounterparts.
Tax Watch, Edition 2, March 2016 EY | 6
Disappointingly, thegovernment has failed toexplain why these new powersare required.
2. Access to remote information
The discussion document fails to address:
► Whether the information would be obtained directly fromthird-party storage entities, or by compelling taxpayers toprovide either the information or access to the information(such as compelling a taxpayer to share passwords toenable access to information).
► The sanctions or penalties that would be imposed on third-parties or taxpayers who refuse to provide access toinformation.
Where to from here?
EY Law Limited’s (EY Law) Tax Controversy practice madesubmissions on each of those proposals. In our view, theproposals should not progress as no identifiable need exists toextend Inland Revenue’s existing powers, especially in light ofthe additional compliance costs that would be imposed onbusiness.
Submissions closed on 12 February 2016, and Inland Revenue ispresently considering its position. There are, no indication yetas to next steps but EY Law will monitor any developmentsclosely.
If you’d like to discuss these proposals, talk to us.
Kirsty Keating,Leader – EY Law,[email protected];Tel: +64 274 899 090
Tori Sullivan,Director, Tax Controversy – EY Law,[email protected];Tel: +64 274 899 734
Tax Watch, Edition 2, March 2016 EY | 7
Inland Revenue flexes itsinformation gathering powers
Inland Revenue was responsiblefor 4,670 requests to the 10companies in just three months.
Privacy CommissionerTransparency Reporting trialhighlights use of section 17
Government agencies made nearly12,000 requests for personal informationfrom 10 New Zealand companies lastyear, according to a new Office of thePrivacy Commissioner report.
The Privacy Commissioner’sTransparency Reporting Trial has foundthat Inland Revenue is the governmentagency that is making the most requeststo businesses for customers’ information.
Inland Revenue was responsible for 4,670requests to the 10 companies in justthree months.
The trial included ten companies, whichall produced standardized transparencyreporting information for the periodAugust to October 2015.
Transparency Reporting Trialreveals trends in informationrequests
The report offers insights into the volumeof information requests, the agenciesmaking requests, and the material andcustomers that are most frequentlytargeted by requests.
The trial results have confirmed there aresignificant compliance costs associatedwith government information requests.
Findings highlight the need to ensure thatyour business has sound practices forprocessing information requests. All staffmembers processing the requests should
have sufficient training and knowledge tofulfill statutory obligations.
The report has also highlighted anincreasing international trend towardscompanies beginning to publish their own‘transparency reports’.
These reports discuss how the companyresponded to information requests, withthe aim of allaying consumer anxiety anddistrust over how their personalinformation is dealt with.
Inland Revenue responsible forlion’s share of requests
Over the course of the trial, the tencompanies received an immense 11,799requests for their customers’ information.
Inland Revenue’s tally of 4,670 put itahead of the Police (3,513 requests) andthe Ministry of Social Development(3,150 requests). Unsurprisingly, themost frequent information gatheringpower exercised by any agency wassection 17 of the Tax Administration Act1964.
Most often, Inland Revenue maderequests to investigate the correctness ofa taxpayer’s position, but also in somecircumstances to gain information uponliquidations or insolvencies.
Account requests the mostcommon
The most common type of informationrequest was an “account request”: arequest for all information held about aspecified person, such as their name,address, subscriber services,transactional information orcommunications.
Less common were “content requests”for information such as email andtelephone records, “transaction requests”
for data such as the number of times aneftpos card was used or to provide bankaccount statements, and “bulk requests”for information held on an entire class ofpeople, such as all customers whoaccessed a specified service over a timeperiod.
Noncompliance only for requestsfor information not held
The trial showed a compliance rate of95.8 per cent amongst the participatingcompanies, compared to an overseascompliance rate of 63 per cent. However,the true rate of compliance for the NewZealand companies was effectively 100per cent, as the reason for non-compliance with a request was almostsolely because the company could notcomply on the basis that it did not holdthe requested information. This appearsto be a result of government agenciesrequesting information from multiplecompanies, without first determiningwhether the person investigated isactually a customer of the business.
We think tax transparency is onthe rise
Take control of your communicationsapproach and make sure that you’ve gotthe systems in place to handleinformation requests. Talk to us to findout more.
David Snell,Executive Director, [email protected],Tel: +64 21 845 361
Tax Watch, Edition 2, March 2016 EY | 8
Know where your clients are taxresident? You’ll soon need to.
Increased reporting on foreigntax residents lies in store forfinancial institutions with NewZealand’s implementation of theAutomatic Exchange ofInformation (AEOI) agreements.
Automatic Exchange ofInformation’s impact on NewZealand
2015 saw the first round of reporting byfinancial institutions of client informationto Inland Revenue. Under the ForeignAccount Tax Compliance Act (FATCA),Inland Revenue passes the information onto the United States government.
Not to be outdone, the OECD isimplementing a global AEOI for taxpurposes, citing growing global concernsregarding offshore tax evasion.
FATCA is United States-specific legislationand focuses on United States citizens andentities abroad. But AEOI has muchbroader application and focuses on thetax residency of the person or entityrather than citizenship.
New Zealand’s role in AEOI
In October 2014, the Minister of Revenueannounced New Zealand’s intent toimplement the AEOI. A furtherannouncement was made in February2016 seeking consultation onimplementation and bringing the startdate forward to 1 July 2017 (previously 1January 2018).
Information exchange with otherjurisdictions must commence bySeptember 2018.
To implement AEOI, the OECD has drafteda Common Reporting Standard (CRS) andModel Competent Authority Agreements(MCAAs). Given the intention for these tobe standardised globally, the documentsleave little opportunity for tailoring byNew Zealand authorities.
Apart from a few key areas on whichInland Revenue wants submissions on(such as due diligence, informationcollection and the information reporting),it currently considers that there is noneed to offer New Zealand-specificmaterial on AEOI as there is sufficientOECD guidance.
Entities affected by AEOI
Under CRS, a broad range of financialservices entities are required to conductdue diligence, including, but not limited tobanks, brokers, custodians, investmentvehicles, managed entities and insurancecompanies.
There are differences between thedefinitions for FATCA purposes and thoseused for CRS purposes. It will beimportant to revalidate your FATCAclassifications in the context of the CRS.You cannot simply rely on your FATCAanalysis.
Tax Watch, Edition 2, March 2016 EY | 9
You’ll need to know (or askyour clients to self-certify) thetax residence of all yourclients.
Information to be collected andreported
Due diligence is conducted on financialaccounts to identify reportable accountsand undocumented accounts under AEOI.Reportable accounts are accounts held bya tax resident (person or entity) ofanother reportable jurisdiction.
In other words, you’ll need to know (orask your clients to self-certify) the taxresidence of all your clients.
As with FATCA, there are provisions forhow to deal with undocumented accounts(where the institution is unable to obtaininformation from the holder) and duediligence procedures will vary based uponwhether accounts are pre-existing (pre 30June 2017), new (post 1 July 2017) andwhether an account holder is a person orentity. Inland Revenue’s issues paperseeks consultation regarding some of thedue diligence procedures in New Zealand.
Hurdles to overcome
One of the key issues facing New Zealandauthorities relates to the confidentialexchange of information and ensuringinformation reported under AEOI remainsconfidential when reported to anotherjurisdiction. Further work will be requiredby the relevant authorities on this.
For reporting entities, the main impactwill be the compliance costs of AEOIrequirements. Financial institutions willneed to start planning to meet theupcoming implementation date of 1 July2017. Discussions to determine whetherthe financial institution is a reporting ornon-reporting institution should beunderway, as well as discussions aroundimplementation for conducting duediligence and reporting.
If you would like to discuss the AEOIrequirements or tax policy in general, giveus a call.
Matthew [email protected]: +64 274 899 279
Gary BurrSenior [email protected]: +64 21 682 920
Suzanne BharadeSenior Consultant
Tax Watch, Edition 2, March 2016 EY | 10
New Australian GST rules fornon-residents
The new law will catch NewZealand businesses supplyingservices to end consumers (“B2Csupplies”) within the AustralianGST net.
Wins and losses for New Zealandbusiness
New Zealand will have the “Netflix tax”from 1 October 2016. Australia ismoving in the same direction.
A law change proposed there aims attaxing cross border supplies of digitalproducts and other imported services.
The new law will catch New Zealandbusinesses supplying services to endconsumers (“B2C supplies”) within theAustralian GST net.
At the same time, a number of measureswill provide relief for New Zealandbusinesses supplying services to businesscustomers in Australia (“B2B supplies”).
Some New Zealand businesseswill lose
The proposed legislation aimed at taxingcross border supplies of digital productsand other imported services will impactthe following:
• New Zealand operators supplyingdigital products such as downloadsof books, movies and music to endconsumers in Australia
• New Zealand suppliers supplyingtraditional services to endconsumers in Australia. Examplesinclude supplies of insurance andconsultancy services, and
• New Zealand suppliers with a mix ofB2C and B2B supplies. B2B supplies
will only be outside the scope ofAustralian GST if appropriateevidence is held regarding the GSTregistration status of the customeris held. Those suppliers with amixture of B2B and B2C supplies willneed to actively manage theirAustralian GST compliance.
Gains for other New Zealandbusinesses
Simplification measures are beingintroduced for B2B supplies. Changesinclude:
• Existing GST registrations - someNew Zealand suppliers alreadyregistered for GST may find thattheir supplies are no longer subjectto Australian GST. This may providean opportunity to be removed fromthe Australian GST regime.
• Services performed in Australia andleasing activities - relief is providedin certain circumstances wherebyservices or leased goods areprovided to Australian businesscustomers. In this case theAustralian customer may berequired to account for GST underthe reverse charge rules.
• Installation contracts – relief isprovided in situations where goodsare installed or assembled by thesupplier in Australia, but the supplieris not the importer of the goods.
• Incurring GST at 10% - servicesacquired from Australian suppliersmay no longer be subject toAustralian GST at 10% as a result ofextending the GST-free provisions(the Australian equivalent for zero-rating). These include warrantyservices and services supplied to anon-resident but provided to anAustralian business.
• GST free supplies - New Zealandsuppliers may not need to registerfor Australian GST if they only makeGST-free supplies, such as exportsfrom Australia, and
• Imports of goods – where importershave difficulty establishing actualfreight and insurance costs, it willpossible to apply an uplift to thecustoms value of the goods to makeit easier to declare these costs.
When are the changes due tocome into effect?
The proposed legislation to capture B2Csupplies of services to Australianconsumers is expected to be effectivefrom 1 July 2017.
The proposed legislation aimed to providesimplification for B2B supplies couldreceive Royal Assent by June 2016resulting in new rules being effective bythe end of the year.
If you need help assessing the impact ofthese changes, contact our indirect taxteam.
Paul SmithPartnerIndirect Tax LeaderTel: +64 274 899 866
Geng ZhengSenior ManagerIndirect TaxTel: +64 274 899 769
Tax Watch, Edition 2, March 2016 EY | 11
Research and development(R&D) tax benefits & bodycorporate GST rules become law
Bill took a full year to passthrough Parliament
The long overdue enactment of theTaxation (Annual Rates for 2015-16,Research and Development, and RemedialMatters) Act 2016 (“the Act”) means keyproposals on Research and Development(“R&D”) tax benefits and body corporateGST rules have now become law.
Research and development taxbenefits
The Act aims to help emerging start-upbusinesses by allowing them a timingbenefit for their R&D tax losses. The R&Dtax benefits are backdated, so apply from1 April 2015.
For more information on these changes,see our previous tax watch article on theR&D benefits.
[Subheading]: Body corporate GST rulesclarified and other changes
In addition the Act includes:
• New rules for New Zealand’s 13,800bodies corporate to provideassurance on their GST position
• Rules giving greater flexibility tousers of tax pooling funds
• Changes intended to reduce long-term child support debt
• Changes to Working for Families taxcredits to clarify some rules andreduce compliance costs forrecipients of the scheme.
If you’d like to know more about howthese changes could affect you or yourbusiness, talk to us.
Darren WhitePartner – Private Client ServicesTel: +64 9 300 8140
Paul SmithPartnerIndirect Tax LeaderTel: +64 274 899 866
Tax Watch, Edition 8, September 2015 EY | 12
Tax watch in brief
PUB00241: Draft InterpretationStatement - Unit trusts mayhave single unit holders
This draft interpretation statementoutlines Inland Revenue’s position onsingle unit holders of unit trusts. Itconcludes that it is possible for a unittrust to have a single unit holder providedthe trust scheme/arrangement is either“made for the purpose” or “has theeffect” of providing multiple unit holderswith facilities. Comments are due by 21March.
PUB00260: QWBA – Proceedsfrom sale of land acquired for apurpose or with an intention ofdisposal considered income
This draft item concerns the proceeds ofthe sale of land where the land wasacquired with the purpose or intention ofdisposal. The proceeds of the sale areconsidered income under s CB 6 of theIncome Tax Act 2007 unless exclusionsapply. Comments are due by 7 April.
PUB00227: QWBA – Proceedsfrom the sale of gold bullion isincome
This QWBA concludes that proceeds frominvesting in gold bullion are income forincome tax purposes under s CB 4 of theIncome Tax Act 2007. Comments are dueby 7 April.
ED0184: Filing an IR10 andsection 108 of the TaxAdministration Act 1994
This draft operational statement explainsthat Inland Revenue prefers taxpayers tobring income to the attention of theCommissioner through filing an IR10,rather than through attaching financialstatements. Comments are due by 25March.:
Special determinations S44 andS45
These two determinations concern thespreading of income and expenditureunder varied intra-group debtarrangements and under variousparticipants’ debt arrangements. Theyprovide certain companies with analternative method to the IFRS financialreporting method in s EW 15D forallocating income and expenditure fromintra-group financial arrangements.
National standard costs forspecified livestock determination2016
The determination provides the nationalstandard costs for specified livestock forthe 2015/2016 income year. It concernsspecified livestock that taxpayers haveelected to value under the scheme for theincome year.
Depreciation rate for geothermaland thermal powerhouses set
This provisional determination sets theprovisional depreciation rate forgeothermal and thermal powerhouses. Itadds new asset classes to thesecategories:
• Power generation and electricalreticulation; and
• Buildings and structures.
The determination applies from the 2012income year.
Determination FDR 2016/01:H20 Feeder Fund
This determination applies to shares heldin the H20 Feeder Fund (“the Fund”),which are considered attributing interestsin a foreign investment fund (FIF).Applicable from the 2017 income year,the determination requires investors touse the fair dividend rate method tocalculate their FIF income derived fromthe fund.
Public consultation Determinations
Product rulings
Product ruling for Harbour FundII GP Ltd
This ruling applies to a fundingagreement between Harbour Fund II GPLtd (“the Fund”) and litigation claimantsto a class action against James Hardieentities. The Fund agrees to pay for alllegal and other costs incurred by theclaimants in exchange for a share of anyproceeds resulting from the litigation.
Product ruling released forMBIE
The ruling applies to an annual levycharged by the Minister ofCommunications and InformationTechnology, who is responsible for theadministration of theTelecommunications Act 2001. MBIEcollects the levy. The ruling applies from01 November 2014 to 01 November2017.
Regulations
Reduced fringe benefit tax(FBT) rate for employment-related loans
The FBT rate for employment-relatedloans has decreased from 5.99% to5.77%. The new rate applies from thebeginning of 2016.
Internationaldevelopments
Multilateral CompetentAuthority Agreement (MCAA)signed
As at 27 January, 79 jurisdictions -including New Zealand - have signed theMCAA. The purpose of the MCAA is tolay out the rules and proceduresrequired for Competent Authorities toautomatically exchange Country-by-Country reports under Action 13 of theOECD BEPS Action Plan.
New Zealand-Samoa double taxagreement (DTA) now in force
The New Zealand-Samoa DTA, whichreplaces the New Zealand-Samoa taxinformation exchange agreement and itssupplementary agreement, has comeinto force. It applies to withholdingtaxes from 1 February, and generallyapplies for other provisions from 1 Aprilin New Zealand and 1 January inSamoa.
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