The Finance and Revenue Minister released a consultation document regarding BEPS – Strengthening interest limitation rules and also inviting public submissions on proposals to improve New Zealand’s thin capitalization rules on 3rd March 2017. The submission date for closing is 18th April 2017.
According to the proposal to amend the thin capitalization rules by:
- Introduce a de minimis test for the inbound thin capitalization rules
- Introduce a special rule for infrastructure projects controlled by a single non-resident
- reducing the ability of companies owned by a group of non-residents to use related-party debt
- removing the ability to use asset valuations for the thin capitalization rules that differ from those reported in a firm’s financial accounts
- ratifying some remedial matters.
