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Is amalgamation the best structure for company growth?

2025-03-08T03:56:16+00:00November 19th, 2024|Articles, Business Strategy, IRD|

As businesses expand, a common decision is whether to create new companies to accommodate new ventures, risks, products and/or acquisitions. A well-designed group structure enables a ‘parent’ company to create distinct entities that operate independently. This approach has several benefits - it provides flexibility as it allows control and visibility over each entity's direction, [...]

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Inland Revenue activity increasing in 2024

2024-08-16T06:46:14+00:00August 16th, 2024|Uncategorized|

After a relatively quiet few years through the Covid pandemic, Inland Revenue’s (IR) audit activity has slowly started to increase over the past few years. In 2021, IR’s campaign had a focus on the real estate sector, where the concern was around real estate agents claiming a disproportionately large amount of expenses relative to [...]

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Non-BAU transaction: IRD technical decision.

2024-08-16T06:09:01+00:00August 16th, 2024|Uncategorized|

BAU is a phrase that is used to describe “business as usual”. It is a good barometer of whether anything strange or unusual has occurred or whether things have been BAU. Invariably, non BAU transactions will occur: an insurance payout, a large asset purchase, a fine or a penalty. This then leads to the [...]

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Tax concessions – ‘donated trading stock’.

2024-08-16T06:04:48+00:00August 16th, 2024|Uncategorized|

Prior to March 2020, in most cases, if a business donated trading stock it resulted in 'deemed income' equivalent to its market value. This resulted in the receiving business being taxed on a deemed profit margin, even though no cash was received. The 'donated trading stock rule' was initially introduced by IR to counter tax avoidance and address [...]

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Employee Share Schemes – devil in the detail.

2024-08-16T05:57:26+00:00August 16th, 2024|Uncategorized|

For businesses that trade through a company, circumstances might arise in which the 'shareholders consider selling a minority stake in the company' to a key employee or group of employees. This could be to ensure key talent is ‘locked in’ for the long term, a means of succession or to link effort to reward. [...]

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Gen-AI – a leap forward and new considerations.

2024-07-09T22:44:47+00:00July 9th, 2024|Uncategorized|

Artificial intelligence (AI) is the new buzzword at the moment, with business leaders touting its importance and the significant impact it will have on the way we conduct business. The reality is that AI has been around for a while, but in the past few years has taken a great leap in terms of its [...]

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New bright-line rules. Blood relative transfers.

2024-07-09T22:40:31+00:00July 9th, 2024|Uncategorized|

Changes to bright-line rules Along with changes to the interest deductibility rules, legislation has been passed which repeals the current bright-line tests, replacing them with a new (or old) 2-year test. There were previously three separate bright-line tests which applied to the sale of residential land: Land acquired on or after 27 March 2021 [...]

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Changes to GST for the platform economy.

2024-07-09T22:33:19+00:00July 9th, 2024|Uncategorized|

In March 2023, legislation in relation to the platform economy was passed, affecting the GST treatment of services made through an electronic marketplace from 1 April 2024. We saw something similar back in 2019, where the GST rules on imported goods were amended to treat operators of online marketplaces as liable for returning GST, as [...]

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Trust Disclosure regime – Insights from the first year.

2024-02-16T23:52:55+00:00February 16th, 2024|Articles|

After the introduction of the Trust Disclosure rules in March 2022, in November 2023 Inland Revenue released a high-level summary (in the form of a 40-page report) of insights from the first year of reporting. While tax advisors and clients alike may have begrudgingly completed the disclosures initially, the statistics may prove to be [...]

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De facto relationship or not?

2024-02-16T23:52:23+00:00February 16th, 2024|Articles|

The Working for Families Tax Credit (WFFTC) is a notoriously complex scheme when it comes to determining eligibility and quantifying entitlement. This leads you to wonder how well the scheme is policed by Inland Revenue, and whether fraud is able to ‘fly under the radar’. Accordingly, it was heartening to see a case brought [...]

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