New Zealand Inland Revenue expands monitoring of large taxpayers

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

New Zealand Inland Revenue expands monitoring of large taxpayers

Sponsored by

sponsored-firms-russel-mcveagh.png
intl-updates-small.jpg

The New Zealand Inland Revenue has announced that it will be increasing the number of large taxpayers that it monitors as part of its Basic Compliance Package (BCP). Inland Revenue's announcement comes at a time of increased media and political attention on the tax affairs of foreign-owned multinational groups.

lester.jpg

James Lester

Approach towards large taxpayer compliance

All large taxpayers are subject to an annual compliance review by Inland Revenue. The BCP requires taxpayers to supply information to Inland Revenue each year, including details of the group's structure, its financial statements and tax reconciliations. When the BCP was first introduced, Inland Revenue said it would allow greater macro-analysis of industries and the identification of variations by jurisdiction. Multinational groups could, according to Inland Revenue, expect to receive more tailored information requests and audit inquiries as a result.

Since 2012, around 600 New Zealand and foreign-owned groups have been subject to the BCP. In addition to the BCP, the compliance activities of the largest 50 corporate taxpayers are account managed by Inland Revenue on a one-to-one basis.

Expansion of the BCP

From 2017, the number of groups subject to the BCP will increase to around 900, including all foreign-owned multinational groups that have a turnover of more than NZ$30 million ($21 million). This represents a significant expansion of the BCP as a compliance tool, highlighting Inland Revenue's preference for receiving comprehensive and standardised information relating to a group's tax affairs over and above the information provided in annual tax returns.

As indicated above, the announcement coincides with questions raised by the media and opposition members of parliament about the declining number of audits carried out by Inland Revenue on large taxpayers. Inland Revenue's statement on the measure on September 30 acknowledged that the "no surprises environment" created by the BCP has reduced the need for formal audits on large enterprises to be undertaken.

OECD's guidance on tax control frameworks

Inland Revenue's Large Enterprises Update (August 2016) recorded Inland Revenue's support for the OECD's Guidance on Tax Control Frameworks, recently released by the organisation 's Forum on Tax Administration (FTA guidance). Inland Revenue considers that the FTA guidance applies particularly to large enterprises, and recommends that corporate boards of directors put in place documented tax strategies as well as systems, procedures and resources to manage tax risk as a means of "setting the right tone from the top".

Inland Revenue recognises that a tax strategy will depend upon the particular circumstances of that business and the industry in question. Inland Revenue's update does refer specifically, however, to the Business and Industry Advisory Committee's (BIAC) Statement of Tax Principles for International Business. BIAC's statement covers tax planning and transparency principles, including that international businesses:

  • Should only engage in tax planning that is aligned with commercial and economic activity and ensure it does not lead to an abusive result;

  • Should interpret relevant tax laws in a reasonable way, consistent with a relationship of "co-operative compliance" with tax authorities; and

  • Be open and transparent with tax authorities in each jurisdiction about their tax affairs and provide the relevant, reasonably requested information (subject to appropriate confidentiality provisions) that is necessary to enable a reasonable review of possible tax risk.

James Lester (james.lester@russellmcveagh.com)

Russell McVeagh

Tel: +64 4 819 7755

Website: www.russellmcveagh.com

more across site & shared bottom lb ros

More from across our site

Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
Gift this article