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General anti-avoidance rules and double tax agreements: A New Zealand perspective
Wednesday, 24 March 2010, 5:30pm to 7:00pm
Professor Craig Elliffe, Chair of the Department of Commercial Law at the University of Auckland.
Lecture Theatre 2, Rutherford House, Victoria University of Wellington, 23 Lambton Quay, Wellington.
Often for tax purposes, different countries treat a transaction in ways that are quite inconsistent. Recently, the New Zealand High Court in Westpac Banking Corporation v Commissioner of Inland Revenue, considered the tax consequences of a structured finance transaction with cross-border implications, and upheld the “process, known as tax arbitrage” terming it “a settled feature of international financing arrangements.” The phenomenon offers significant potential for tax planning and opportunities for tax avoidance.
The seminar will consider the effectiveness of the general anti-avoidance rule (GAAR) in the New Zealand Income Tax Act in the context of cross-border transactions or arrangements. A vital issue is about the impact of double tax agreements on an international transaction or arrangement when the tax authorities invoke the GAAR.
The invitation to the seminar is available here. Please feel free to forward the invitation to interested parties within your organisation.
Please RSVP attendance for catering purposes by latest Tuesday 23 March. Light refreshments will be available after the seminar.
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