In addition, certain foreign-sourced dividends paid by an Australian company to a non-resident shareholder are also exempt from Australian withholding tax.
Note: the New Zealand Government is in discussion with Australian tax officials over trans-Tasman tax issues. In August 2000 the Treasurers of both countries announced that they were going to examine the issue of "triangular taxation". This concerns the situation where New Zealand shareholders in an Australian company operating in New Zealand are unable to access franking credits, and vice versa. The idea is to be able to recognise certain franking credits for New Zealand tax purposes.
Therefore, in your situation there may be relief to the extent the Australian company operates in New Zealand and the dividends arise from that operation.
Income Tax Act 1994, ss CF 6,
LC 6, NG 1(2)(a).
2001 New Zealand Master Tax Guide, 26-185.
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