There is a lot of information on the net about the benefits of Australian residents (for tax purposes) holding NZ property through an NZ foreign trust. This requires a non-NZ resident settlor, an NZ resident trustee (could be an NZ incorporated company though there seems to be an issue under the Australia/NZ double tax treaty if the shareholders/directors of the trusteee company are Australian residents and caution required) and non-NZ resident benefiaries.
It seems that trust beneficiaries (or the trustee where the income and/or capital gain have not been distributed) are currently only subject to NZ income tax on NZ sourced trust income (and no capital gains tax is payable in Australia or NZ on capital gains realised on the sale of NZ trust property).
The benefits of such a structure are touted by several NZ law firms see: -
http://www.fmlaw.co.nz/publications/trust_articles/NZ_trust_prop_invest.htm
NZ tax authorities are considering reporting details of NZ foreign sourced trusts with Australian resident settlors to the Australian taxation office see proposal below.
"25 November 2004
Future information requirements for foreign trusts with
New Zealand-resident trustees: amended proposal
1. On behalf of the New Zealand government, tax policy officials are conducting a
second round of consultation on proposed changes that would require foreign trusts
with New Zealand-resident trustees to provide certain information to New Zealand’s
Inland Revenue Department.
2. The amended proposal outlined here is intended to strike the correct balance
between ensuring that New Zealand is in a position to meet its commitments under its
double tax agreements, and ensuring that the obligations imposed on foreign trusts are
not onerous and do not give rise to legitimate privacy concerns.
3. The amended proposal differs from the previous proposal in that New Zealandresident
trustees of foreign trusts will be required to provide only limited information
to Inland Revenue upon appointment and to maintain records in New Zealand so
information can be provided to Inland Revenue if requested. Under the previous
proposal, trustees would have been required to provide Inland Revenue with an
annual disclosure statement, including a full set of financial accounts.
Background
4. In June 2004 Dr Michael Cullen, the Minister of Finance and the Minister of
Revenue, agreed, in principle, to introduce certain record-keeping and filing
requirements for foreign trusts with New Zealand-resident trustees. The reason for
proposing such requirements was to enable New Zealand to provide information on
such foreign trusts when other tax authorities request it – as many are entitled to do
under double tax agreements signed with New Zealand. Officials were directed to
undertake consultation on the proposal.
5. A number of submissions we received in response to the first round of
consultation suggested the development of a system to regulate New Zealand-resident
trustees who provide trustee services to foreign trusts. From a tax policy perspective,
the tax rules should not regulate who can provide or offer trustee services.
6. Although we do not favour regulating who can provide trustee services, there is
a case for requiring at least one New Zealand-resident trustee of each foreign trust to
be a member of an acceptable professional body whose members are subject to a code
of conduct, ethics and disciplinary measures. Under the amended proposal, the onus
will be on the New Zealand-resident trustee to maintain and provide the necessary
records. Given this, requiring at least one New Zealand-resident trustee to be a
member of an accepted professional body will provide assurance to Inland Revenue
2
that a trustee has the necessary expertise to maintain records of the required standard
and will comply with the law.
7. Once consultation on the amended proposal is complete, the Minister will make
final policy decisions based on officials’ recommendations and feedback received
from the second round of consultation.
Summary of the proposal
8. The proposal will require New Zealand-resident trustees to:
• provide limited information to Inland Revenue upon appointment as
trustee of a foreign trust;
• maintain certain information relating to the trust in New Zealand and
provide this information to Inland Revenue if requested; and
• at least one New Zealand-resident trustee of a foreign trust to be a
member of an acceptable professional body such as an accounting or legal
body.
9. New Zealand-resident trustees who fail to disclose the requested information to
Inland Revenue and to maintain records in New Zealand for New Zealand tax
purposes will be subject to sanctions. They may be liable to New Zealand tax and
criminal penalties for failing to keep records or provide the information requested.
10. The proposal is intended to ensure that New Zealand is in a position to meet its
commitments, under its double tax agreements, to co-operate with other tax
jurisdictions. We want to achieve this in a way that minimises any impact on
legitimate transactions and commerce, as well as legitimate privacy concerns.
11. There is no intention to change the current New Zealand income tax treatment
of foreign trusts that meet the necessary requirements under this proposal.
12. Under New Zealand law, a foreign trust is one that has had no New Zealandresident
settlor from the later of 17 December 1987 or the date upon which the first
settlement was made to the trust. The income of a foreign trust is not liable to
New Zealand income tax as long as the settlor remains a non-resident, no trust income
is earned in New Zealand and no beneficiary of the trust is a New Zealand resident.
Information to be disclosed to Inland Revenue
13. New Zealand-resident trustees of foreign trusts will be required to provide the
following information to Inland Revenue upon their appointment, or the enactment of
the proposal in relation to existing appointments:
• the name of the trust or other identifying feature(s) such as the trust
number and/or the date of settlement of the trust;
3
• the name and contact details of the trustee(s); and
• the country of residence of the settlor(s) if the country is specified in the
law or by way of Regulation (see paragraph 16-18).
14. If any of this information changes and a trustee is aware of the change, the
trustee will be obliged to inform Inland Revenue so the information can be updated.
15. A specific statutory disclosure requirement similar to section 59 of the Tax
Administration Act 1994 will be required.
16. The New Zealand-resident trustee will be required to disclose the country of
residence of the settlor to Inland Revenue only if the country requesting it is explicitly
specified in New Zealand law.
17. Inland Revenue has agreed to provide automatically to the Australian Taxation
Office, information relating to foreign trusts that have a New Zealand-resident trustee
and an Australian-resident settlor. To ensure that Inland Revenue is in a position to
provide this information automatically, New Zealand-resident trustees will be
required to inform Inland Revenue if a trust has an Australian-resident settlor.
Australia is the only country to which New Zealand is currently proposing to provide
information on an automatic basis.
18. Trustees will be expected to take reasonable care to determine if a settlor is
resident in Australia, based on the information that is available to them. If, for lack of
information, a trustee fails to inform Inland Revenue that a settlor is resident in
Australia, it will not result in the trustee being penalised for non-compliance. If a
trustee does not take reasonable care to determine that a settlor is an Australian
resident or they do not provide that information to Inland Revenue, the trustee may be
subject to penalties for failure to disclose the required information.
Record-keeping requirements
19. Trustees will be required to keep certain business records in New Zealand for at
least seven years after the end of the income year to which they relate. If a trust
ceases to have a New Zealand-resident trustee, the requirement to keep records for
seven years will remain.
20. The records should:
• correctly explain the transactions of the trust;
• enable the trust’s financial position to be accurately determined at any
time;
• allow financial statements to be prepared;
• include source documentation relating to sales, purchases and other
transactions, and the assets and liabilities of the trust;
4
• provide details of settlements on the trust and distributions to beneficiaries
(including their name and address); and
• include a copy of the trust deed.
21. Section 22 of the Tax Administration Act 1994 will be amended accordingly.
Determining the residence of the trustee
22. The rules for determining if a person (an individual or a company) is a
New Zealand resident are set out in sections OE 1 and OE 2 of the Income Tax Act
1994 and 2004.
Individuals
23. Trustees of foreign trusts who are individuals (as opposed to trustee companies)
will be treated as New Zealand residents if:
• they maintain a ‘permanent place of abode’ in New Zealand, whether or
not they also have a permanent place of abode outside New Zealand; or
• they have been present in New Zealand for more than 183 days in any 12-
month period.
24. To cease New Zealand residence, they must be absent from New Zealand for at
least 325 days in any 12-month period.
25. The ‘permanent place of abode’ test takes precedence over the others. For
instance, individuals who maintain a permanent place of abode but have been absent
from New Zealand for more than 325 days in a 12-month period remain New Zealand
residents.
Companies
26. A trustee of a foreign trust that is a company will be treated as a New Zealand
resident if the company:
• is incorporated in New Zealand; or
• has a head office in New Zealand; or
• has its centre of management in New Zealand; or
• the control of the company by its directors, acting in their capacity as
directors, is exercised in New Zealand, whether or not decision-making by
directors is confined to New Zealand.
5
Additional requirements for a trustee to be treated as a New Zealand-resident
trustee
27. To be treated as a New Zealand-resident trustee, at least one trustee of a foreign
trust will also be required to be a member of a professional body that is acceptable to
Inland Revenue. In the case of a trustee company, a New Zealand-resident director of
the company will be required to be a member of such a professional body.
28. Under the amended proposal, the onus will be on the New Zealand-resident
trustee to maintain and provide the necessary records. Given this, requiring at least
one New Zealand-resident trustee to be a member of an accepted professional body
will provide assurance to Inland Revenue that a trustee has the necessary expertise to
maintain records of the required standard and will comply with the law.
29. Acceptable professional bodies are likely to include, but will not necessarily be
limited to, certain accounting and legal professional institutes or societies.
Membership of these types of professional bodies is usually restricted to individuals
who hold relevant qualifications. We would be interested in readers’ views on the
types of professional bodies that should be included as acceptable.
30. Once legislation is enacted, Inland Revenue will develop administrative
guidelines to assist in determining which professional bodies will be acceptable.
Acceptable professional bodies are likely to be those that require their members to
comply with the following requirements as a condition of membership:
• adhere to the professional code of conduct and ethics;
• be subject to a disciplinary process that enforces compliance with the code
of conduct and ethics; and
• follow certain ‘best practice’ guidelines.
31. In addition, members of such professional bodies would provide, or could
provide, trustee services as part of being a member of that professional body.
Requests for information about trusts from other countries
Australia
32. When information provided by a trustee indicates that a settlor of the trust is an
Australian resident, Inland Revenue will:
• request further information from the trustee (such as financial records,
distributions to beneficiaries and the identity of the settlor); and
• automatically release the information to the relevant Australian Taxation
Office on an annual basis.
6
Other signatory countries to double tax agreements
33. Information will be provided to other signatory countries to double tax
agreements on a case-by-case request basis, when Inland Revenue considers that there
are valid grounds for requesting the information. In accordance with the OECD
Model Treaty and Commentary on Article 26, Inland Revenue will not entertain
general ‘fishing expeditions’ from tax treaty partners for information on foreign trusts.
Rules governing information collected
34. Any information provided to Inland Revenue by the New Zealand-resident
trustees of foreign trusts will be subject to the existing tax secrecy laws. Section 81 of
the Tax Administration Act 1994 prevents Inland Revenue from providing
information to a foreign jurisdiction except as permitted by section 81(4)(k) –
[reciprocal law or concession or reciprocal arrangement].
Ensuring compliance
35. To ensure compliance with the proposed disclosure rules, a foreign trust with a
New Zealand-resident trustee will be subject to New Zealand tax on its worldwide
income if a trustee fails to disclose the required information to Inland Revenue (see
paragraph 13). Trustees that do not maintain or provide information when requested
may be subject to prosecution and criminal penalties.
Non-compliant foreign trusts subject to New Zealand tax on their worldwide
income
36. If a New Zealand-resident trustee of a foreign trust fails to disclose the required
information to Inland Revenue, the taxation of the trust will be based on the residence
of the trustee rather than the settlor. The worldwide income of the trust will be treated
as trustee income, and taxed at 33%.
37. Failure to disclose the required information will create a tax liability against
trustees. Trustees who expose their trusts to such a liability may also be breaching
their fiduciary obligation to the beneficiaries of the trust, and therefore may be
personally liable to the beneficiaries. Disclosure of the required information removes
this liability.
38. If a New Zealand-resident trustee takes reasonable care in determining that a
trust is not a foreign trust and it is later found to be one, there will be no retrospective
liability for tax on the worldwide income of the trust if the trustee provides the
required information as soon as possible upon determining that it is a foreign trust.
Tax will be imposed prospectively if the trustee fails to provide the required
information once the foreign trust status of the trust is established.
39. Taxing non-compliant foreign trusts on their worldwide income is intended to
encourage trustees to comply with the disclosure requirements, not to impose tax on
such foreign trusts.
7
Imposing a criminal penalty for failure to keep records or provide information
40. Trustees who fail to keep records or disclose information to Inland Revenue, as
required under this proposal, will be subject to existing penalties under the Tax
Administration Act 1994. Under this Act, a fine of up to $50,000 can be imposed, on
conviction, for failure to provide information.
41. The penalty for non-compliance is imposed upon conviction. This requires the
non-compliance to be detected, proceedings begun and conviction entered.
How to make a submission on the proposal
42. We would appreciate receiving any comments you have on the proposal by
23 December 2004.
43. Any written comments should be forwarded to:
Foreign trusts proposal
C/- Deputy Commissioner, Policy
Policy Advice Division
Inland Revenue Department
P O Box 2198
Wellington
New Zealand
44. If making a submission in electronic form please put ‘Foreign trusts proposal’ in
the subject line. The electronic address is:
[email protected]
45. Please note that submissions may be the subject of a request under
New Zealand’s Official Information Act 1982. The withholding of particular
submissions on the grounds of privacy, or for any other reason, will be determined in
accordance with that Act. If there is any part of your submission which you consider
could be properly withheld under that Act (for example, for reasons of privacy),
please indicate this clearly in your submission."
Ajax
It seems that trust beneficiaries (or the trustee where the income and/or capital gain have not been distributed) are currently only subject to NZ income tax on NZ sourced trust income (and no capital gains tax is payable in Australia or NZ on capital gains realised on the sale of NZ trust property).
The benefits of such a structure are touted by several NZ law firms see: -
http://www.fmlaw.co.nz/publications/trust_articles/NZ_trust_prop_invest.htm
NZ tax authorities are considering reporting details of NZ foreign sourced trusts with Australian resident settlors to the Australian taxation office see proposal below.
"25 November 2004
Future information requirements for foreign trusts with
New Zealand-resident trustees: amended proposal
1. On behalf of the New Zealand government, tax policy officials are conducting a
second round of consultation on proposed changes that would require foreign trusts
with New Zealand-resident trustees to provide certain information to New Zealand’s
Inland Revenue Department.
2. The amended proposal outlined here is intended to strike the correct balance
between ensuring that New Zealand is in a position to meet its commitments under its
double tax agreements, and ensuring that the obligations imposed on foreign trusts are
not onerous and do not give rise to legitimate privacy concerns.
3. The amended proposal differs from the previous proposal in that New Zealandresident
trustees of foreign trusts will be required to provide only limited information
to Inland Revenue upon appointment and to maintain records in New Zealand so
information can be provided to Inland Revenue if requested. Under the previous
proposal, trustees would have been required to provide Inland Revenue with an
annual disclosure statement, including a full set of financial accounts.
Background
4. In June 2004 Dr Michael Cullen, the Minister of Finance and the Minister of
Revenue, agreed, in principle, to introduce certain record-keeping and filing
requirements for foreign trusts with New Zealand-resident trustees. The reason for
proposing such requirements was to enable New Zealand to provide information on
such foreign trusts when other tax authorities request it – as many are entitled to do
under double tax agreements signed with New Zealand. Officials were directed to
undertake consultation on the proposal.
5. A number of submissions we received in response to the first round of
consultation suggested the development of a system to regulate New Zealand-resident
trustees who provide trustee services to foreign trusts. From a tax policy perspective,
the tax rules should not regulate who can provide or offer trustee services.
6. Although we do not favour regulating who can provide trustee services, there is
a case for requiring at least one New Zealand-resident trustee of each foreign trust to
be a member of an acceptable professional body whose members are subject to a code
of conduct, ethics and disciplinary measures. Under the amended proposal, the onus
will be on the New Zealand-resident trustee to maintain and provide the necessary
records. Given this, requiring at least one New Zealand-resident trustee to be a
member of an accepted professional body will provide assurance to Inland Revenue
2
that a trustee has the necessary expertise to maintain records of the required standard
and will comply with the law.
7. Once consultation on the amended proposal is complete, the Minister will make
final policy decisions based on officials’ recommendations and feedback received
from the second round of consultation.
Summary of the proposal
8. The proposal will require New Zealand-resident trustees to:
• provide limited information to Inland Revenue upon appointment as
trustee of a foreign trust;
• maintain certain information relating to the trust in New Zealand and
provide this information to Inland Revenue if requested; and
• at least one New Zealand-resident trustee of a foreign trust to be a
member of an acceptable professional body such as an accounting or legal
body.
9. New Zealand-resident trustees who fail to disclose the requested information to
Inland Revenue and to maintain records in New Zealand for New Zealand tax
purposes will be subject to sanctions. They may be liable to New Zealand tax and
criminal penalties for failing to keep records or provide the information requested.
10. The proposal is intended to ensure that New Zealand is in a position to meet its
commitments, under its double tax agreements, to co-operate with other tax
jurisdictions. We want to achieve this in a way that minimises any impact on
legitimate transactions and commerce, as well as legitimate privacy concerns.
11. There is no intention to change the current New Zealand income tax treatment
of foreign trusts that meet the necessary requirements under this proposal.
12. Under New Zealand law, a foreign trust is one that has had no New Zealandresident
settlor from the later of 17 December 1987 or the date upon which the first
settlement was made to the trust. The income of a foreign trust is not liable to
New Zealand income tax as long as the settlor remains a non-resident, no trust income
is earned in New Zealand and no beneficiary of the trust is a New Zealand resident.
Information to be disclosed to Inland Revenue
13. New Zealand-resident trustees of foreign trusts will be required to provide the
following information to Inland Revenue upon their appointment, or the enactment of
the proposal in relation to existing appointments:
• the name of the trust or other identifying feature(s) such as the trust
number and/or the date of settlement of the trust;
3
• the name and contact details of the trustee(s); and
• the country of residence of the settlor(s) if the country is specified in the
law or by way of Regulation (see paragraph 16-18).
14. If any of this information changes and a trustee is aware of the change, the
trustee will be obliged to inform Inland Revenue so the information can be updated.
15. A specific statutory disclosure requirement similar to section 59 of the Tax
Administration Act 1994 will be required.
16. The New Zealand-resident trustee will be required to disclose the country of
residence of the settlor to Inland Revenue only if the country requesting it is explicitly
specified in New Zealand law.
17. Inland Revenue has agreed to provide automatically to the Australian Taxation
Office, information relating to foreign trusts that have a New Zealand-resident trustee
and an Australian-resident settlor. To ensure that Inland Revenue is in a position to
provide this information automatically, New Zealand-resident trustees will be
required to inform Inland Revenue if a trust has an Australian-resident settlor.
Australia is the only country to which New Zealand is currently proposing to provide
information on an automatic basis.
18. Trustees will be expected to take reasonable care to determine if a settlor is
resident in Australia, based on the information that is available to them. If, for lack of
information, a trustee fails to inform Inland Revenue that a settlor is resident in
Australia, it will not result in the trustee being penalised for non-compliance. If a
trustee does not take reasonable care to determine that a settlor is an Australian
resident or they do not provide that information to Inland Revenue, the trustee may be
subject to penalties for failure to disclose the required information.
Record-keeping requirements
19. Trustees will be required to keep certain business records in New Zealand for at
least seven years after the end of the income year to which they relate. If a trust
ceases to have a New Zealand-resident trustee, the requirement to keep records for
seven years will remain.
20. The records should:
• correctly explain the transactions of the trust;
• enable the trust’s financial position to be accurately determined at any
time;
• allow financial statements to be prepared;
• include source documentation relating to sales, purchases and other
transactions, and the assets and liabilities of the trust;
4
• provide details of settlements on the trust and distributions to beneficiaries
(including their name and address); and
• include a copy of the trust deed.
21. Section 22 of the Tax Administration Act 1994 will be amended accordingly.
Determining the residence of the trustee
22. The rules for determining if a person (an individual or a company) is a
New Zealand resident are set out in sections OE 1 and OE 2 of the Income Tax Act
1994 and 2004.
Individuals
23. Trustees of foreign trusts who are individuals (as opposed to trustee companies)
will be treated as New Zealand residents if:
• they maintain a ‘permanent place of abode’ in New Zealand, whether or
not they also have a permanent place of abode outside New Zealand; or
• they have been present in New Zealand for more than 183 days in any 12-
month period.
24. To cease New Zealand residence, they must be absent from New Zealand for at
least 325 days in any 12-month period.
25. The ‘permanent place of abode’ test takes precedence over the others. For
instance, individuals who maintain a permanent place of abode but have been absent
from New Zealand for more than 325 days in a 12-month period remain New Zealand
residents.
Companies
26. A trustee of a foreign trust that is a company will be treated as a New Zealand
resident if the company:
• is incorporated in New Zealand; or
• has a head office in New Zealand; or
• has its centre of management in New Zealand; or
• the control of the company by its directors, acting in their capacity as
directors, is exercised in New Zealand, whether or not decision-making by
directors is confined to New Zealand.
5
Additional requirements for a trustee to be treated as a New Zealand-resident
trustee
27. To be treated as a New Zealand-resident trustee, at least one trustee of a foreign
trust will also be required to be a member of a professional body that is acceptable to
Inland Revenue. In the case of a trustee company, a New Zealand-resident director of
the company will be required to be a member of such a professional body.
28. Under the amended proposal, the onus will be on the New Zealand-resident
trustee to maintain and provide the necessary records. Given this, requiring at least
one New Zealand-resident trustee to be a member of an accepted professional body
will provide assurance to Inland Revenue that a trustee has the necessary expertise to
maintain records of the required standard and will comply with the law.
29. Acceptable professional bodies are likely to include, but will not necessarily be
limited to, certain accounting and legal professional institutes or societies.
Membership of these types of professional bodies is usually restricted to individuals
who hold relevant qualifications. We would be interested in readers’ views on the
types of professional bodies that should be included as acceptable.
30. Once legislation is enacted, Inland Revenue will develop administrative
guidelines to assist in determining which professional bodies will be acceptable.
Acceptable professional bodies are likely to be those that require their members to
comply with the following requirements as a condition of membership:
• adhere to the professional code of conduct and ethics;
• be subject to a disciplinary process that enforces compliance with the code
of conduct and ethics; and
• follow certain ‘best practice’ guidelines.
31. In addition, members of such professional bodies would provide, or could
provide, trustee services as part of being a member of that professional body.
Requests for information about trusts from other countries
Australia
32. When information provided by a trustee indicates that a settlor of the trust is an
Australian resident, Inland Revenue will:
• request further information from the trustee (such as financial records,
distributions to beneficiaries and the identity of the settlor); and
• automatically release the information to the relevant Australian Taxation
Office on an annual basis.
6
Other signatory countries to double tax agreements
33. Information will be provided to other signatory countries to double tax
agreements on a case-by-case request basis, when Inland Revenue considers that there
are valid grounds for requesting the information. In accordance with the OECD
Model Treaty and Commentary on Article 26, Inland Revenue will not entertain
general ‘fishing expeditions’ from tax treaty partners for information on foreign trusts.
Rules governing information collected
34. Any information provided to Inland Revenue by the New Zealand-resident
trustees of foreign trusts will be subject to the existing tax secrecy laws. Section 81 of
the Tax Administration Act 1994 prevents Inland Revenue from providing
information to a foreign jurisdiction except as permitted by section 81(4)(k) –
[reciprocal law or concession or reciprocal arrangement].
Ensuring compliance
35. To ensure compliance with the proposed disclosure rules, a foreign trust with a
New Zealand-resident trustee will be subject to New Zealand tax on its worldwide
income if a trustee fails to disclose the required information to Inland Revenue (see
paragraph 13). Trustees that do not maintain or provide information when requested
may be subject to prosecution and criminal penalties.
Non-compliant foreign trusts subject to New Zealand tax on their worldwide
income
36. If a New Zealand-resident trustee of a foreign trust fails to disclose the required
information to Inland Revenue, the taxation of the trust will be based on the residence
of the trustee rather than the settlor. The worldwide income of the trust will be treated
as trustee income, and taxed at 33%.
37. Failure to disclose the required information will create a tax liability against
trustees. Trustees who expose their trusts to such a liability may also be breaching
their fiduciary obligation to the beneficiaries of the trust, and therefore may be
personally liable to the beneficiaries. Disclosure of the required information removes
this liability.
38. If a New Zealand-resident trustee takes reasonable care in determining that a
trust is not a foreign trust and it is later found to be one, there will be no retrospective
liability for tax on the worldwide income of the trust if the trustee provides the
required information as soon as possible upon determining that it is a foreign trust.
Tax will be imposed prospectively if the trustee fails to provide the required
information once the foreign trust status of the trust is established.
39. Taxing non-compliant foreign trusts on their worldwide income is intended to
encourage trustees to comply with the disclosure requirements, not to impose tax on
such foreign trusts.
7
Imposing a criminal penalty for failure to keep records or provide information
40. Trustees who fail to keep records or disclose information to Inland Revenue, as
required under this proposal, will be subject to existing penalties under the Tax
Administration Act 1994. Under this Act, a fine of up to $50,000 can be imposed, on
conviction, for failure to provide information.
41. The penalty for non-compliance is imposed upon conviction. This requires the
non-compliance to be detected, proceedings begun and conviction entered.
How to make a submission on the proposal
42. We would appreciate receiving any comments you have on the proposal by
23 December 2004.
43. Any written comments should be forwarded to:
Foreign trusts proposal
C/- Deputy Commissioner, Policy
Policy Advice Division
Inland Revenue Department
P O Box 2198
Wellington
New Zealand
44. If making a submission in electronic form please put ‘Foreign trusts proposal’ in
the subject line. The electronic address is:
[email protected]
45. Please note that submissions may be the subject of a request under
New Zealand’s Official Information Act 1982. The withholding of particular
submissions on the grounds of privacy, or for any other reason, will be determined in
accordance with that Act. If there is any part of your submission which you consider
could be properly withheld under that Act (for example, for reasons of privacy),
please indicate this clearly in your submission."
Ajax
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