Tax Residency: IRD Interpretation Statement

This newly published by IRD  Interpretation Statement explains the residence rules in the Income Tax Act 2007, and applies from 1 April 2014.  The analysis in this Interpretation Statement is in three parts. The first part (from [17]) deals with the rules governing the residence of natural persons (individuals), and discusses the relationship between those rules and the residence articles contained in New Zealand’s double taxation agreements (DTAs).

It also discusses the transitional resident rules.  The second part (from [308]) explains the residence rules for companies. It also explains the consequences of a company being a dual resident, and briefly discusses the relationship of the company residence rules to the controlled foreign company (CFC) regime. The final part (from [432]) of this Interpretation Statement deals with residence and the taxation regime for trusts.


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March 18th, 2014