New Zealand Inland Revenue has opened consultation on a draft interpretation statement clarifying GST treatment of arranging and brokering financial products by intermediaries.
It outlines when such activities qualify as exempt “arranging” under the Goods and Services Tax Act 1985 and how they are distinguished from “advising” services.
New Zealand Inland Revenue has released a draft interpretation statement for public consultation titled “GST – Arranging and brokering financial products” on 21 May 2026.
The statement guides when intermediaries or brokers involved in the supply of financial products will be treated as making an exempt supply of financial services for GST purposes through “arranging”, rather than providing “advising” services. It explains the meaning of “arranging” and sets out how GST applies to intermediary and broker activities connected to financial products.
It clarifies that the interpretation statement operates alongside Interpretation Statement IS0052 (Financial Planning Fees—GST Treatment), which deals with the GST treatment of financial planning fees, and does not replace it or any successor statement.
Under section 3(1)(l) of the Goods and Services Tax Act 1985, the involvement of an intermediary or broker will constitute an exempt supply of “arranging” where their activities amount to direct involvement in an integral part of the supply chain intended to bring about the supply of a financial service. This requires that the intermediary’s role is a precursor to the provision of a financial service that the recipient has already decided to obtain, is intended to facilitate that supply, and is not subject to an overriding decision by a party other than the financial service provider. This distinction separates activities that implement a chosen financial service from earlier speculative or promotional activities that are too remote from the actual provision of the service.
It further states that whether the activities of an intermediary or broker constitute a single composite supply or multiple supplies must first be determined in line with IS 18/04: Goods and Services Tax – Single supply or multiple supplies. If the activities qualify as “arranging”, the supply will be exempt; otherwise, it may be taxable unless it is reasonably incidental and necessary to an exempt supply made by the intermediary or broker.
Activities that amount to “advising thereon” are excluded from the exemption. Where both exempt and taxable supplies are made for a single global consideration, apportionment may be required. Each case must be assessed based on its specific facts.
The deadline for submissions on the draft interpretation statement is 2 July 2026.
