The Relationship Between Controlled Foreign Corporation Rules And Tax Sparing Provisions In Tax Treaties New Zealand Case
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The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case
Author | : B.J. Arnold |
Publisher | : |
Total Pages | : |
Release | : 2018 |
Genre | : |
ISBN | : |
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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.
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