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A Historical Review of the CFC & FIF Regimes: Part One 1987 to 1 December 2003

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dc.contributor.author Dunbar, David
dc.date.accessioned 2007-11-20T20:00:51Z
dc.date.accessioned 2022-07-05T01:19:36Z
dc.date.available 2007-11-20T20:00:51Z
dc.date.available 2022-07-05T01:19:36Z
dc.date.copyright 2004
dc.date.issued 2004
dc.identifier.uri https://ir.wgtn.ac.nz/handle/123456789/18582
dc.description.abstract The CFC & FIF regimes were originally enacted to prevent New Zealand taxpayers using tax havens to avoid or defer their New Zealand tax obligations. However both regimes contain a number of provisions that have not been adopted by any of the major OECD countries or any of NZ major trading partners. For example, the CFC regime does not contain an active income exemption and the FIF regime often taxes unrealised capital gains. Those features have lead to widespread criticism and a range of taxpayer responses to ameliorate the negative impact the current rules have on legitimate off shore trade and investment decisions. Part one of this article examines: the tax planning opportunities which both regimes were designed to curtail, the behavioural responses of taxpayers to the perceived harshness of the current law, and the McLeod Committee recommendations, which were designed to achieve a more appropriate balance between taxpayers, legitimate commercial offshore investment decisions and the ongoing threat posed by tax havens. en_NZ
dc.format pdf en_NZ
dc.language.iso en_NZ
dc.publisher Te Herenga Waka—Victoria University of Wellington en_NZ
dc.relation.ispartofseries No. 13 en_NZ
dc.relation.ispartofseries Working Paper en_NZ
dc.subject Tax avoidance en_NZ
dc.subject Taxation law en_NZ
dc.subject Taxation methods en_NZ
dc.title A Historical Review of the CFC & FIF Regimes: Part One 1987 to 1 December 2003 en_NZ
dc.type Text en_NZ
vuwschema.contributor.unit Centre for Accounting, Governance and Taxation Research en_NZ
vuwschema.contributor.unit School of Accounting and Commercial Law en_NZ
vuwschema.subject.anzsrcfor 150199 Accounting, Auditing and Accountability not elsewhere classified en_NZ
vuwschema.subject.marsden 390118 Taxation Law en_NZ
vuwschema.type.vuw Working or Occasional Paper en_NZ
vuwschema.subject.anzsrcforV2 350199 Accounting, auditing and accountability not elsewhere classified en_NZ

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