CA ANZ has considered the proposals in the Bill and make the following observations:

Foreign Investment Fund (FIF) – Revenue Account Method (RAM): While the introduction of RAM is a positive step, we emphasise that these changes alone are unlikely to achieve the Government’s stated objective of attracting globally mobile talent and migrants to New Zealand. The scope of RAM is narrow and does not fully address liquidity and valuation challenges faced by new residents. Without complementary reform of the financial arrangement rules (Subpart EW), including simplification of methods, and alignment of tax with cash flows, the policy intent will remain under-realised.

Fringe Benefit Tax (FBT): We support practical clarifications in the Bill but urge Government to proceed with broader reform of the FBT regime. Current rules, particularly for motor vehicles and minor benefits, are complex and outdated. Comprehensive reform is needed to simplify compliance, reduce costs, and ensure fairness. In the interim, we do not support removing gift cards from the unclassified benefit category, as this would increase compliance costs unnecessarily.

Trust Disclosure Rules: We support repealing sections 59BA and 59BAB of the Tax Administration Act 1994 but strongly recommend that the Commissioner does not replicate these rules under general powers. Any ongoing data collection should be proportionate, purpose-driven, and mindful of the significant trust data Inland Revenue will already hold by 2026–27.

Retention of Section 17GB (Tax Administration Act): We support retaining section 17GB to enable Inland Revenue to collect data necessary for evidence-based policy development. However, its application should be subject to clear safeguards, including relevance, necessity, proportionality, privacy protections, and consultation with affected sectors.

CA ANZ also offers key submissions on tax treatment of New Zealand visitors, GST and unincorporated joint ventures and Employee Share Schemes.