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Technical tax area Ngā tūmomo whakataunga me ngā aratohu

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Inland Revenue issues public rulings to interpret how a tax law applies to taxpayers and specific types of arrangements. Taxpayers whose circumstances match those in a ruling may apply it, but are not obliged to do so.

If you calculate your tax liability according to an applicable public binding ruling, we must assess your tax according to that ruling. A public ruling applies only to the particular taxation law and arrangement set out in the ruling, and only for a specified period. If there is any material difference between the facts in the ruling and your actual arrangement, the ruling does not apply.

Public rulings are issued by the Office of the Chief Tax Counsel (OCTC) business group of Inland Revenue. Please contact us if you have any inquiries about public rulings.

All the public rulings issued to date for the current year are displayed here by year, number (BR Pub), title, and status.


BR Pub 19/05: Income tax - treatment of alteration to rights attached to shares under section CB 4; BR Pub 19/06: Income tax - treatment of a disposal of shares with altered rights under section CB 4

The rulings concern an arrangement where a shareholder holds shares in a company and the shares were acquired for the purpose of disposal. Subsequently, the rights attached to the shares are altered and the following applies: The shares are in a company registered under the Companies Act 1993; the alteration is not structured as a cancellation and issue of shares. To avoid doubt, the rulings do not include an arrangement where s BG 1 applies to void the arrangement. The rulings conclude that an alteration of share rights does not result in a disposal of personal property for the purposes of s CB 4, and the time of acquisition of the shares where the rights attached to them are altered after acquisition is the time the shares were acquired before the alteration.

Ruling applies from: These rulings will apply for an indefinite period beginning on 1 April 2020


BR Pub 19/05 and BR Pub 19/06 - PDF format (175kb | 11 pages)


BR Pub 19/04: Income tax – application of the employee share scheme rules to employer issued crypto-assets provided to an employee

This Ruling follows on from three Public Rulings that were issued recently: BR Pub 19/01: Income tax – salary and wages paid in crypto-assets, BR Pub 19/02: Income tax – bonuses paid in crypto-assets and BR PUB 19/03: Income tax - employer issued crypto-assets provided to an employee. This Ruling considers whether the employee share scheme rules apply to some types of employer-issued crypto-assets provided to employees.

Ruling applies from: This Ruling will apply for a period of three years beginning on 1 December 2019.


BR Pub 19/04 - PDF format (226kb | 18 pages)


BR Pub 19/03: Income tax - employer issued crypto-assets provided to an employee

This Ruling follows on from two Public Rulings that were issued recently: BR Pub 19/01: Income tax – salary and wages paid in crypto-assets and BR Pub 19/02: Income tax – bonuses paid in crypto-assets. It considers how FBT applies where cryptocurrency issued by an employer is provided to an employee.

Ruling applies from: This ruling will apply for a period of three years beginning on 30 July 2019.


BR Pub 19/03 - PDF format (131kb | 13 pages)


BR Pub 19/02: Income tax – bonuses paid in crypto-assets

This ruling considers whether bonuses received by employees in crypto-assets are subject to PAYE.

Ruling applies from: This ruling will apply for a period of three years beginning on 1 September 2019.


BR Pub 19/02 - PDF format (125kb | 12 pages)


BR Pub 19/01: Income tax – salary and wages paid in crypto-assets

This ruling considers whether regular remuneration received by employees in crypto-assets are subject to PAYE.

Ruling applies from: This ruling will apply for a period of three years beginning on 1 September 2019.


BR Pub 19/01 - PDF format (186kb | 18 pages)


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