According to CA ANZ, the issues paper considers multiple aspects. Two areas in particular are significant and far-reaching:

• the tax treatment of unrelated business income derived by a registered charity (discussed in chapter 2), and
• the tax rules for not-for-profit entities’ member transactions (discussed in chapter 4).

Most New Zealand households will be a member of, connected to, support or volunteer in a not-for-profit (e.g. sports club, book club) or charity. Given the general nature of certain statements made in the issues paper, CA ANZ is concerned its release has created confusion and uncertainty.

In CA ANZ’s view, the absence of credible data and information to support the proposal to amend the charities business income exemption is a significant shortcoming.

CA ANZ has made key submissions on several aspects of the paper, including:

• the charity business income tax exemption,
• donor-controlled charities,
• not-for-profit and friendly society member transactions, 
• income tax and FBT exemptions, and
• tax simplification for volunteers.