New Zealand


  • Service: Tax
  • Type: Business and industry issue
  • Date: 19/02/2013

Contact us

Rebecca Armour

Partner - Tax

+64 9 367 5926


Our tax advisory team has the skills and commitment to help you to be competitive and compliant in all areas of business tax.

Submission - INS 0117 - Income Tax: Residence 

We believe that providing taxpayers and advisors with greater certainty around matters of residence is important both to ensure the security and integrity of the New Zealand tax base and to encourage voluntary compliance.

In light of the importance of, and the growing need for, a consistent but practical approach we have outlined in some degree of detail our concerns with Inland Revenue’s approach to residence of individuals in the IS.


Download Now
PDF files require Adobe Reader to view

Residence is a critical feature of the New Zealand tax system.


It determines whether an individual, or other entity, is exposed to New Zealand tax on worldwide income, or only New Zealand sourced income.


Since the Commissioner’s last statement on income tax residence, published in 1989 in Public Information Bulletin 180 (“PIB 180”), we have seen significant changes in the mobility of individuals and the way that business is conducted internationally.


We agree PIB 180 needs to be updated. In our view, this is needed to accommodate modern work practices and the circumstances of expatriates and migrants.


It is also needed to improve consistency in the

positions adopted by Inland Revenue’s frontline staff.


In practice, we are seeing widely differing interpretations depending on which part of Inland Revenue, or which office, is addressing the issue..  

Tax submissions - Submissions on draft tax legislation, Government discussion documents and issues papers, & various tax interpretation statements released by the New Zealand Inland Revenue.