On 7 may 2015, the New Zealand Inland Revenue Department published an officials’ issues paper on possible changes to the non-resident withholding tax (NRWT 15%) rules on related-party debt. The purpose of the changes is to counter the avoidance of NRWT through the unintended use of exemptions.

Preventing Associated Parties Accessing the AIL Rules

An exemption from NRWT is provided if the pay…