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KPMG is proud to be sponsoring an award category at this year’s HSBC NZCTA Chinese Business Awards.
Smarter procurement: keeping you up to speed with developments in national and international infrastructure procurement and partnering.
The FATCA rules are wide-ranging and will require non-U.S. financial institutions, investment entities and insurance companies to report details on their US clients and owners.
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Onwards and upwards? 2012 saw profitability for many institutions improve to near record levels.
We have a unique opportunity to plan and rebuild New Zealand’s second largest city to meet the needs of generations to come. Funding such an undertaking is just one of the challenges before us.
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Knock-out for the Commissioner? Issue 2, October 2010
A knock-out win for the Commissioner, or a points decision? Either way, the case has some important implications
The Supreme Court dismissed unanimously an appeal by Ian Penny and Gary Hooper (“Penny & Hooper”) against the Court of Appeal judgement, in favour of the Commissioner of Inland Revenue, that the payment of non-market salaries to the two orthopaedic surgeons, by their respective companies, amounted to tax avoidance.
The decision confirms that the adoption of a particular business structure is not tax avoidance, in and of itself, and payment of a non-market salary may be justified in some circumstances.
However, the result will change if tax is more than an incidental driver of the overall arrangement.
The decision also confirms that the Parliamentary contemplation test remains a crucial part of the tax avoidance landscape, although its application remains uncertain in our view.
The taxmail PDF analyses the Penny & Hooper Supreme Court decision in greater detail.
If you have any questions on the above, please speak to your usual KPMG advisor or contact:
John CantinPartner - TaxKPMGPhone: +64 4 816 4518
jfcantin@kpmg.co.nz
Murray SareliusPartner - Tax KPMGPhone: +64 9 363 3458
mvsarelius@kpmg.co.nz
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