The New Zealand Trust as a Vehicle for Foreign Investment
Title | The New Zealand Trust as a Vehicle for Foreign Investment PDF eBook |
Author | John Prebble QC |
Publisher | |
Pages | 11 |
Release | 2015 |
Genre | |
ISBN |
Sections HH 1 and HH 8 of the New Zealand Income Tax Act 1976 contain a special regime for the taxation of trusts. Income that is distributed by the trustee is taxed in the hands of the beneficiary, and income that is accumulated is taxed to the trustee. The mere fact of the trustee being resident in New Zealand does not attract tax, instead the regime takes a substantive, economics-based approach to the taxation of trusts. This article outlines the effects of this regime on people wishing to use a trust in New Zealand as a vehicle for foreign investment. As at 2009, the special regime for the taxation of trusts in the 1976 Act appears as subpart HC of the Income Tax Act 2007. Sections HC 17-HC 23 deal with the tax treatment of amounts that beneficiaries receive from a trust, sections HC 24-26 with the tax treatment of trustee income and sections 27-29 with the tax treatment of settlors. Section CV 13 makes it clear when these amounts will be “income”
New Zealand Income Tax Act 2007 (2013 edition)
Title | New Zealand Income Tax Act 2007 (2013 edition) PDF eBook |
Author | CCH New Zealand Ltd |
Publisher | CCH New Zealand Limited |
Pages | 3149 |
Release | 2013-07-01 |
Genre | Business & Economics |
ISBN | 1775470059 |
The Income Tax Act 2007 is consolidated to 1 January 2013 and includes a comprehensive summary of amendments, detailed history notes and indexes.
International Taxation of Trust Income
Title | International Taxation of Trust Income PDF eBook |
Author | Mark Brabazon |
Publisher | Cambridge University Press |
Pages | 0 |
Release | 2022-06-30 |
Genre | Law |
ISBN | 9781108729178 |
In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.
International Taxation of Trust Income
Title | International Taxation of Trust Income PDF eBook |
Author | Mark Brabazon |
Publisher | Cambridge University Press |
Pages | 417 |
Release | 2019-05-02 |
Genre | Law |
ISBN | 1108492258 |
This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
International Taxation of Low-Tax Transactions [2009] - High-Tax Jurisdictions
Title | International Taxation of Low-Tax Transactions [2009] - High-Tax Jurisdictions PDF eBook |
Author | Dennis Campbell |
Publisher | Lulu.com |
Pages | 602 |
Release | 2009-08-12 |
Genre | Law |
ISBN | 0557092205 |
2009 RELEASE: "International Taxation of Low-Tax Transactions, High Tax Jurisdictions" - A three-volume set with nearly 1,200 pages, offers tax specialists from North and South America, Europe, Asia and the Pacific, and the Middle East who examine the treatment by high-tax countries of transactions originating from and holdings based in low-tax jurisdictions, providing an essential tool for practitioners dealing with the crossborder movement of capital and other assets. The publication is replaced by updated volumes annually. Order Low-Tax Jurisdictions, Volumes I and II, to complete the set. A 25% discount applies to a subscription for three years of updates. Discounts are applied after purchase by rebate from publisher.
The Statutes of New Zealand
Title | The Statutes of New Zealand PDF eBook |
Author | New Zealand |
Publisher | |
Pages | 978 |
Release | 2009 |
Genre | Law |
ISBN |
Trust that Trust
Title | Trust that Trust PDF eBook |
Author | Pat Rotherham |
Publisher | |
Pages | |
Release | 2019 |
Genre | Family trusts |
ISBN | 9780473502577 |