Read the draft items

You can access the draft consultation items on Inland Revenue's Tax Technical Website.

Income Tax – Non-resident software suppliers’ payments derived from New ZealandThe main proposals include:

This interpretation guideline addresses payments made by New Zealand entities to non-residents in connection with software transactions. Its focus is on explaining the principles behind the classification of common types of software transactions. It also outlines the relevant income tax implications of those transactions under New Zealand law, including the impact of double tax agreements (DTAs).

Consultation closes 31 October 2026 

Income tax – Depreciation of low-value assets

This interpretation statement explains the income tax rules that allow a taxpayer to claim a depreciation loss deduction for the full capital cost of an item of depreciable property where the item’s cost does not exceed a specified threshold. It also explains how the rules work when a taxpayer purchases items of property together, and how depreciation recovery income can arise when they dispose of such items.

Consultation closes 20 November 2026 

Income tax: Continuity of business activities – carrying forward losses arising in the income year of ownership continuity breach

2007 apply to losses arising in the income year in which a company breaches the continuity of ownership requirements. Uncertainty has arisen about whether that income year is an “earlier income year” under s IB 3(2), such that the losses can be carried forward. This QWBA confirms losses incurred in the income year of an ownership continuity breach can be carried forward. It is relevant to companies that have both an ownership continuity breach and a tax loss arising in the income year of the breach.

Consultation closes 27 November 2026 

Goods and Services Tax – Compulsory zero-rating of land rules

This interpretation statement explains the compulsory zero-rating of land rules and sets out what information a purchaser must provide to a vendor where a supply wholly or partly consists of land. It also explains what to do when the GST treatment is incorrect, including where a purchaser provides incorrect information.

Consultation closes 27 November 2026 

Mutual associations (including clubs and societies)

This draft operational statement explains the income tax treatment of amounts societies, clubs and other not-for-profit associations receive from members, other than amounts subject to a specific tax exemption such as for charities or sports clubs.

It describes how the mutual association provisions override the principle of mutuality meaning that supplies of trading stock and services to members may be taxable.  In addition, following legislative changes proposed in the Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill, membership subscriptions, fees and levies will generally be exempt income for not-for-profit organisations.  Organisations with net income of less than $10,000, will have no tax liability and may choose not to file tax returns.

The statement applies from 1 April 2027 and will be prospective in application when finalised. 

Consultation closes 11 December 2026