New Zealand


  • Service: Tax
  • Type: Business and industry issue
  • Date: 19/10/2010


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

Taxmail - Closely held company reforms 

Issue 2, October 2010


The Government has released draft legislation changing the taxation treatment of closely-held companies.


We are pleased to see that the latest proposals preserve many features of the existing qualifying company regime.

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The closely-held company reforms will be introduced progressively, starting with the removal of flow through of losses for loss attributing qualifying companies. 


Taxpayers will also be given a window in which to decide which structure will best meet their needs.   


An interesting development is the Look Through Company (LTC), a tax transparent entity which will offer most of the tax benefits of a limited partnership, but using a company structure. 


Other changes on the way


The Government has also signalled an intention to conduct a wide ranging review of the tax treatment of dividends for closely-held companies. The indications are that this review will be extensive.  We do not expect the resulting changes to take effect prior to the 2012 tax year. 


We are concerned that these changes are being introduced in a piecemeal manner.  Taxpayers will be required to select an entity type without full knowledge of the downstream consequences of such choices.


KPMG will provide further clarity when the final form of the changes is known.


If you have any questions on the above, please speak to your usual KPMG advisor or contact:


John Adams
Director - Tax
Phone: +64 7 858 6541

Anne Edgar
Director - Tax
Phone: +64 3 371 4835

Taxmail - Comment on topical tax issues from KPMG NZ Tax. 

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