DOI: 10.59403/1bar6jk

Abstract

This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand’s CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer’s claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty.

Citation format

ARNOLD, B.J. The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties: A new zealand case. Bulletin for International Taxation, 2018.