New Zealand Inland Revenue expands monitoring of large taxpayers

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

New Zealand Inland Revenue expands monitoring of large taxpayers

Sponsored by

sponsored-firms-russel-mcveagh.png
intl-updates-small.jpg

The New Zealand Inland Revenue has announced that it will be increasing the number of large taxpayers that it monitors as part of its Basic Compliance Package (BCP). Inland Revenue's announcement comes at a time of increased media and political attention on the tax affairs of foreign-owned multinational groups.

lester.jpg

James Lester

Approach towards large taxpayer compliance

All large taxpayers are subject to an annual compliance review by Inland Revenue. The BCP requires taxpayers to supply information to Inland Revenue each year, including details of the group's structure, its financial statements and tax reconciliations. When the BCP was first introduced, Inland Revenue said it would allow greater macro-analysis of industries and the identification of variations by jurisdiction. Multinational groups could, according to Inland Revenue, expect to receive more tailored information requests and audit inquiries as a result.

Since 2012, around 600 New Zealand and foreign-owned groups have been subject to the BCP. In addition to the BCP, the compliance activities of the largest 50 corporate taxpayers are account managed by Inland Revenue on a one-to-one basis.

Expansion of the BCP

From 2017, the number of groups subject to the BCP will increase to around 900, including all foreign-owned multinational groups that have a turnover of more than NZ$30 million ($21 million). This represents a significant expansion of the BCP as a compliance tool, highlighting Inland Revenue's preference for receiving comprehensive and standardised information relating to a group's tax affairs over and above the information provided in annual tax returns.

As indicated above, the announcement coincides with questions raised by the media and opposition members of parliament about the declining number of audits carried out by Inland Revenue on large taxpayers. Inland Revenue's statement on the measure on September 30 acknowledged that the "no surprises environment" created by the BCP has reduced the need for formal audits on large enterprises to be undertaken.

OECD's guidance on tax control frameworks

Inland Revenue's Large Enterprises Update (August 2016) recorded Inland Revenue's support for the OECD's Guidance on Tax Control Frameworks, recently released by the organisation 's Forum on Tax Administration (FTA guidance). Inland Revenue considers that the FTA guidance applies particularly to large enterprises, and recommends that corporate boards of directors put in place documented tax strategies as well as systems, procedures and resources to manage tax risk as a means of "setting the right tone from the top".

Inland Revenue recognises that a tax strategy will depend upon the particular circumstances of that business and the industry in question. Inland Revenue's update does refer specifically, however, to the Business and Industry Advisory Committee's (BIAC) Statement of Tax Principles for International Business. BIAC's statement covers tax planning and transparency principles, including that international businesses:

  • Should only engage in tax planning that is aligned with commercial and economic activity and ensure it does not lead to an abusive result;

  • Should interpret relevant tax laws in a reasonable way, consistent with a relationship of "co-operative compliance" with tax authorities; and

  • Be open and transparent with tax authorities in each jurisdiction about their tax affairs and provide the relevant, reasonably requested information (subject to appropriate confidentiality provisions) that is necessary to enable a reasonable review of possible tax risk.

James Lester (james.lester@russellmcveagh.com)

Russell McVeagh

Tel: +64 4 819 7755

Website: www.russellmcveagh.com

more across site & bottom lb ros

More from across our site

Luxembourg saw the highest increase in tax-to-GDP ratio out of OECD countries in 2023, according to the organisation’s new Revenue Statistics report
Ryan’s VAT practice leader for Europe tells ITR about promoting kindness, playing the violincello and why tax being boring is a ‘ridiculous’ idea
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
A high number of granted APAs demonstrates the Italian tax authorities' commitment to resolving TP issues proactively, experts say
Malta risks ceding tax revenues to jurisdictions that adopt the global minimum tax sooner, the IMF said
The UK and what has been dubbed its ‘second empire’ have been found to be responsible for 26% of all countries’ tax losses by the Tax Justice Network
Ireland offers more than just its competitive corporate tax environment but a reduction in the US rate under a Trump administration could affect the country, experts tell ITR
The ‘big four’ firm was originally prohibited from tendering for government work until December 1 due to its tax leaks scandal, but ongoing investigations into the matter have seen the date extended
Approximately 74% of MAP cases in 2023 reached a full resolution, but new transfer pricing MAP cases fell by 16%
Brazil is looking to impose the OECD’s 15% global minimum tax on multinationals; in other news, PwC is set to pull out of Fiji
Gift this article