Tax Disputes and Rulings
Globally, tax authorities are becoming more sophisticated than ever - sharing information, scrutinising tax positions closer to real time, employing data analytics, requesting considerable volumes of information such as emails, and adopting a distinctly more savvy approach to dispute strategy. New Zealand’s Inland Revenue is no different, and its confidence has been buoyed by a string of successes in the courts. As Inland Revenue increases its activity levels across all sectors, minimising or eliminating the potentially significant cost and disruption of tax disputes is front of mind for business.
Our Tax Disputes and Rulings team has its finger firmly on the pulse, leveraging our depth of expertise and extensive know-how to efficiently, pragmatically and strategically manage - and sensibly resolve - tax disputes for our clients. The team also identifies and addresses tax risk as transactions are being implemented, including through securing the comfort that a binding ruling or indicative view can provide.
Our local and global specialists can:
- assist with Inland Revenue risk reviews, investigations and audits, and co-ordinate forensic (discovery and analytics) support for information requests. For more information on the increasing reliance by Inland Revenue and the courts on peripheral material such as emails, and our forensic capabilities, please refer to Emails: smart ways to manage the potential minefield;
- manage the entire tax dispute process, including settlement negotiations and relevant aspects of litigation support;
- offer Tax Controversy Management software to help multinational companies consistently control and manage tax controversies across multiple jurisdictions;
- seek private/product rulings or indicative views from Inland Revenue, and liaise with appropriate officials where tax outcomes do not resonate from a policy perspective.
- CIR v Trustpower: Unfeasibility expenditure
- Amending return errors: Taxpayer friendly High Court ruling
- High Court awards increased costs and criticises Inland Revenue
- Tax avoidance: Inland Revenue sheds further light on their approach in practice
- Alesco - The pendulum continues to swing in Inland Revenue's favour (PDF)
- A conceptual challenge - The common voting interests and control by any other means tests for association (PDF)
- Emails - Smart ways to manage the potential minefield (PDF)
- Hope for the best, prepare for the audit (PDF)
- Investing in a chance - Trustpower secures a rare taxpayer win in the courts (PDF)
- Know your rights...of non-disclosure (PDF)
- Tax function - positive return on sensible investment (PDF)
- Clarity, controversy, or both: Inland Revenue’s finalised guidance on tax avoidance (PDF)
- Alesco: The pendulum continues to swing in Inland Revenue’s favour (PDF)