Date posted: 25/06/2025

Submission on Thin capitalisation settings for infrastructure

CA ANZ’s feedback on the issues paper

CA ANZ supports Option 2, which proposes a more general rule that applies to third party limited debt.

This option is preferred for several reasons: flexibility and practicality; self-limiting nature; and avoiding picking winners.

Flexibility and Practicality: Option 2 offers greater flexibility and practicality by allowing third party debt without the need for strict definitions of infrastructure. This approach avoids the complexities and ambiguities associated with defining infrastructure and ensures that economically viable projects can proceed without unnecessary barriers.

Self-Limiting Nature: The third-party debt test is inherently self-limiting, as banks and financial institutions will only lend based on the project's economic viability and security. This ensures that only genuinely viable projects receive funding, protecting the tax base while encouraging investment.

Avoiding Picking Winners: By not restricting the rule to specific types of infrastructure, Option 2 avoids the issue of picking winners. It allows a broader range of projects to benefit from the rule, promoting overall economic growth and investment in New Zealand.

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