International Cross Border Taxation Third Edition

Written by international tax law specialist, Professor Craig Elliffe, International and Cross-Border Taxation in New Zealand is a major commentary on New Zealand’s international tax law and double taxation agreements.

The book is designed to provide readers with an understanding of the legal principles and concepts that underpin international tax law and cross-border transactions and practical guidance to assist them to navigate their way through this complex topic.

This much anticipated third edition includes:

• a detailed discussion of the treaty-based anti-avoidance principle purpose test (PPT) and updated guidance on where the Base Erosion and Profit Shifting (BEPS) project has landed and progressed;

• significant changes introduced by the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018, including reforms to the sourcing rules that deem income to be derived from New Zealand in circumstances where that income is attributable to a permanent establishment in New Zealand or is taxable under a New Zealand double tax agreement;

• changes under the Taxation (Annual Rates for 2022–23, Platform Economy, and Remedial Matters) Act 2023, including:

— adjustment of the corporate migration rules to address integrity issues for dual resident Australian/New Zealand companies and permit relief and concessions in certain circumstances for dual resident companies; and

— the introduction of a new definition of a “foreign exemption trust”;

— reforms to application of the PAYE rules where non-resident employers make payments of New Zealand sourced employment income (or of foreign-sourced employment income) to New Zealand resident cross-border workers;

• proposed amendments which expand access to the attributable foreign investment fund (FIF) income method where a person acquires or disposes of an FIF interest;

• updated transfer pricing guidelines;

• proposals to introduce a new digital services tax;

• a new chapter dealing with global minimum tax; and

• much more.

International and Cross-Border Taxation in New Zealand is an invaluable resource for lawyers and accountants, as well as an excellent guide for law students studying this area. It provides guidance to practitioners on many of the difficult problems they encounter. Taxpayers, their advisors, and tax administrators need to understand these types of issues.