On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com>
wrote:
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net
dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are liable) >>>but
Or what about rental property owned by foreigners. Do they pay any
tax to the NZ Govt?
foreign companies operating in New Zealand are liable to pay tax here at the >>>same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a maximum >>>price that a company can charge its overseas susidiaries. This protects the >>>home base country against transferring tax burdens overseas. NZ may have >>>this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New
Zealand taxable income, which depending on your view, may or may not
be the same as "nospam" meant by "the money it earns". During the term
of the last Labour Government rules were changed so that banks now
have to maintain funds in New Zealand to cover prudential reserves for >>their New Zealand operations, and I think they also have to maintain >>systems to enable the banks to keep operating if they ar cut off from
their head offices overseas. That has limited the scope for outrageous >>charging os NZ branches / subsidiaries (transfer pricing) to shift
profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any
event. That may not be the case with all companies - Google has hit
the news internationally (they are making 'voluntary"tax payments to >>various governments), and in New Zealand Apple have made the news for
the low taxes that they pay - in effect they buy product for sale at
just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords -
just as fo many domestic landlords they may be able to defer tax on >>propoerties for a long period, especially if they control borrowing
and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>possible", and probably less than New Zealand owners as they have
greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax toI very much doubt it, that would be unreasonable but they will pay NZ tax on their profit in NZ.
the Australian Govt on the profit it makes in New Zealand?
I'm also trying to find out what tax U.S companies avoid paying to theMoving headquarters is probably not enough, however the cost of the headquarters may be transferred I guess. I know that US companies transfer large cost centres to places like Mexico and to different US states to help their tax position.
U.S. Govt by moving their headquarters to Ireland. As far as I can
see, they avoid paying the U.S tax on their foreign earnings - is
that correct? If so, why should the U.S Govt get a share of the
profit made in a foreign country?
Also, when determining the profit made in a foreign country, how muchPresumably that is set by the laws in the country where the R&D costs reside. I doubt that tax relief is available in one country when the cost is in a different country but there are some strange rules.
of research and development costs are you allowed to claim as part of
the cost of making the product?
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net
dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the moneyNot sure about non-resident landlords (although I suspect they are liable) but
it earns in NZ to the NZ Govt or to the Australian Govt?
Or what about rental property owned by foreigners. Do they pay any
tax to the NZ Govt?
foreign companies operating in New Zealand are liable to pay tax here at the >>same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a maximum >>price that a company can charge its overseas susidiaries. This protects the >>home base country against transferring tax burdens overseas. NZ may have this >>requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New
Zealand taxable income, which depending on your view, may or may not
be the same as "nospam" meant by "the money it earns". During the term
of the last Labour Government rules were changed so that banks now
have to maintain funds in New Zealand to cover prudential reserves for
their New Zealand operations, and I think they also have to maintain
systems to enable the banks to keep operating if they ar cut off from
their head offices overseas. That has limited the scope for outrageous >charging os NZ branches / subsidiaries (transfer pricing) to shift
profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any
event. That may not be the case with all companies - Google has hit
the news internationally (they are making 'voluntary"tax payments to
various governments), and in New Zealand Apple have made the news for
the low taxes that they pay - in effect they buy product for sale at
just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords -
just as fo many domestic landlords they may be able to defer tax on >propoerties for a long period, especially if they control borrowing
and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >possible", and probably less than New Zealand owners as they have
greater ability to show only one side of some transactions.
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com>
wrote:
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net
dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are liable) but
Or what about rental property owned by foreigners. Do they pay any
tax to the NZ Govt?
foreign companies operating in New Zealand are liable to pay tax here at the >>>same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a maximum >>>price that a company can charge its overseas susidiaries. This protects the >>>home base country against transferring tax burdens overseas. NZ may have this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New
Zealand taxable income, which depending on your view, may or may not
be the same as "nospam" meant by "the money it earns". During the term
of the last Labour Government rules were changed so that banks now
have to maintain funds in New Zealand to cover prudential reserves for >>their New Zealand operations, and I think they also have to maintain >>systems to enable the banks to keep operating if they ar cut off from
their head offices overseas. That has limited the scope for outrageous >>charging os NZ branches / subsidiaries (transfer pricing) to shift
profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any
event. That may not be the case with all companies - Google has hit
the news internationally (they are making 'voluntary"tax payments to >>various governments), and in New Zealand Apple have made the news for
the low taxes that they pay - in effect they buy product for sale at
just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords -
just as fo many domestic landlords they may be able to defer tax on >>propoerties for a long period, especially if they control borrowing
and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>possible", and probably less than New Zealand owners as they have
greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax toAs far as I am aware the profits in Australia that count for
the Australian Govt on the profit it makes in New Zealand?
I'm also trying to find out what tax U.S companies avoid paying to the
U.S. Govt by moving their headquarters to Ireland. As far as I can
see, they avoid paying the U.S tax on their foreign earnings - is
that correct? If so, why should the U.S Govt get a share of the
profit made in a foreign country?
Also, when determining the profit made in a foreign country, how much
of research and development costs are you allowed to claim as part of
the cost of making the product?
On Mon, 08 Feb 2016 11:32:08 +1300, nospam <nospam@nospam.nospam>I believe that is completelly incorrect. A US company pays tax in the countries where they operate based on the profit in that company, it is not accumulated back home.
wrote:
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com>As far as I am aware the profits in Australia that count for
wrote:
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net
dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are liable) >>>>but
Or what about rental property owned by foreigners. Do they pay any >>>>>tax to the NZ Govt?
foreign companies operating in New Zealand are liable to pay tax here at >>>>the
same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a >>>>maximum
price that a company can charge its overseas susidiaries. This protects the >>>>home base country against transferring tax burdens overseas. NZ may have >>>>this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New
Zealand taxable income, which depending on your view, may or may not
be the same as "nospam" meant by "the money it earns". During the term
of the last Labour Government rules were changed so that banks now
have to maintain funds in New Zealand to cover prudential reserves for >>>their New Zealand operations, and I think they also have to maintain >>>systems to enable the banks to keep operating if they ar cut off from >>>their head offices overseas. That has limited the scope for outrageous >>>charging os NZ branches / subsidiaries (transfer pricing) to shift
profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any
event. That may not be the case with all companies - Google has hit
the news internationally (they are making 'voluntary"tax payments to >>>various governments), and in New Zealand Apple have made the news for
the low taxes that they pay - in effect they buy product for sale at
just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords -
just as fo many domestic landlords they may be able to defer tax on >>>propoerties for a long period, especially if they control borrowing
and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>>possible", and probably less than New Zealand owners as they have
greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax to
the Australian Govt on the profit it makes in New Zealand?
Australian tax liability would be after payment of New Zealand taxes -
they would make profit from two main areas. First any dividends paid
by the New Zealand operations (for Westpac I suspect that is a New
Zealand company) - they would be treated as for any other New Zealand >dividends for Australian tax. Then there is interest received on any
lending from Austrralian Westpac to NZ Westpac, and charges for other >services. Again they are subject to Australian tax, but may be
deductible for New Zealand tax. I am not an expert on international
taxes though, but I do now that there were investigations some years
ago into whether Australian parent banks were charging fairly for
services provided - NZ banks are now required to be able to operate
with domestic NZ systems for at least a short time.
I'm also trying to find out what tax U.S companies avoid paying to the
U.S. Govt by moving their headquarters to Ireland. As far as I can
see, they avoid paying the U.S tax on their foreign earnings - is
that correct? If so, why should the U.S Govt get a share of the
profit made in a foreign country?
Broadly I think you are correct - the US company becomes a subsidiary
of a global company. A US company is however required to pay tax on
total worldwide income, presumably with some recognition for taxes
paid outside the USA.
All I know about that is that it is very
complicated! - and some nominally US companies pay little tax in New
Zealand (Google and Apple have had the most publicity).
Also, when determining the profit made in a foreign country, how much
of research and development costs are you allowed to claim as part of
the cost of making the product?
Rich80105<rich80105@hotmail.com> wrote:
On Mon, 08 Feb 2016 11:32:08 +1300, nospam <nospam@nospam.nospam>I believe that is completelly incorrect. A US company pays tax in the countries
wrote:
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com> >>>wrote:As far as I am aware the profits in Australia that count for
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net >>>>dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are liable) >>>>>but
Or what about rental property owned by foreigners. Do they pay any >>>>>>tax to the NZ Govt?
foreign companies operating in New Zealand are liable to pay tax here at >>>>>the
same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a >>>>>maximum
price that a company can charge its overseas susidiaries. This protects the
home base country against transferring tax burdens overseas. NZ may have >>>>>this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New
Zealand taxable income, which depending on your view, may or may not
be the same as "nospam" meant by "the money it earns". During the term >>>>of the last Labour Government rules were changed so that banks now
have to maintain funds in New Zealand to cover prudential reserves for >>>>their New Zealand operations, and I think they also have to maintain >>>>systems to enable the banks to keep operating if they ar cut off from >>>>their head offices overseas. That has limited the scope for outrageous >>>>charging os NZ branches / subsidiaries (transfer pricing) to shift >>>>profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any
event. That may not be the case with all companies - Google has hit
the news internationally (they are making 'voluntary"tax payments to >>>>various governments), and in New Zealand Apple have made the news for >>>>the low taxes that they pay - in effect they buy product for sale at >>>>just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords - >>>>just as fo many domestic landlords they may be able to defer tax on >>>>propoerties for a long period, especially if they control borrowing
and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>>>possible", and probably less than New Zealand owners as they have >>>>greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax to
the Australian Govt on the profit it makes in New Zealand?
Australian tax liability would be after payment of New Zealand taxes -
they would make profit from two main areas. First any dividends paid
by the New Zealand operations (for Westpac I suspect that is a New
Zealand company) - they would be treated as for any other New Zealand >>dividends for Australian tax. Then there is interest received on any >>lending from Austrralian Westpac to NZ Westpac, and charges for other >>services. Again they are subject to Australian tax, but may be
deductible for New Zealand tax. I am not an expert on international
taxes though, but I do now that there were investigations some years
ago into whether Australian parent banks were charging fairly for
services provided - NZ banks are now required to be able to operate
with domestic NZ systems for at least a short time.
I'm also trying to find out what tax U.S companies avoid paying to the >>>U.S. Govt by moving their headquarters to Ireland. As far as I can
see, they avoid paying the U.S tax on their foreign earnings - is
that correct? If so, why should the U.S Govt get a share of the
profit made in a foreign country?
Broadly I think you are correct - the US company becomes a subsidiary
of a global company. A US company is however required to pay tax on
total worldwide income, presumably with some recognition for taxes
paid outside the USA.
where they operate based on the profit in that company, it is not accumulated >back home.
All I know about that is that it is very
complicated! - and some nominally US companies pay little tax in New >>Zealand (Google and Apple have had the most publicity).
Also, when determining the profit made in a foreign country, how much
of research and development costs are you allowed to claim as part of
the cost of making the product?
Tony
On Sun, 07 Feb 2016 22:19:23 -0600, Tony <lizandtony at orcon dot netI don't know what you were describing but it was patently wrong!
dot nz> wrote:
Rich80105<rich80105@hotmail.com> wrote:
On Mon, 08 Feb 2016 11:32:08 +1300, nospam <nospam@nospam.nospam>I believe that is completelly incorrect. A US company pays tax in the >>countries
wrote:
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com> >>>>wrote:As far as I am aware the profits in Australia that count for
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net >>>>>dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are >>>>>>liable)
Or what about rental property owned by foreigners. Do they pay any >>>>>>>tax to the NZ Govt?
but
foreign companies operating in New Zealand are liable to pay tax here at >>>>>>the
same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a >>>>>>maximum
price that a company can charge its overseas susidiaries. This protects >>>>>>the
home base country against transferring tax burdens overseas. NZ may have >>>>>>this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New >>>>>Zealand taxable income, which depending on your view, may or may not >>>>>be the same as "nospam" meant by "the money it earns". During the term >>>>>of the last Labour Government rules were changed so that banks now >>>>>have to maintain funds in New Zealand to cover prudential reserves for >>>>>their New Zealand operations, and I think they also have to maintain >>>>>systems to enable the banks to keep operating if they ar cut off from >>>>>their head offices overseas. That has limited the scope for outrageous >>>>>charging os NZ branches / subsidiaries (transfer pricing) to shift >>>>>profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any >>>>>event. That may not be the case with all companies - Google has hit >>>>>the news internationally (they are making 'voluntary"tax payments to >>>>>various governments), and in New Zealand Apple have made the news for >>>>>the low taxes that they pay - in effect they buy product for sale at >>>>>just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords - >>>>>just as fo many domestic landlords they may be able to defer tax on >>>>>propoerties for a long period, especially if they control borrowing >>>>>and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>>>>possible", and probably less than New Zealand owners as they have >>>>>greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax to
the Australian Govt on the profit it makes in New Zealand?
Australian tax liability would be after payment of New Zealand taxes - >>>they would make profit from two main areas. First any dividends paid
by the New Zealand operations (for Westpac I suspect that is a New >>>Zealand company) - they would be treated as for any other New Zealand >>>dividends for Australian tax. Then there is interest received on any >>>lending from Austrralian Westpac to NZ Westpac, and charges for other >>>services. Again they are subject to Australian tax, but may be
deductible for New Zealand tax. I am not an expert on international
taxes though, but I do now that there were investigations some years
ago into whether Australian parent banks were charging fairly for >>>services provided - NZ banks are now required to be able to operate
with domestic NZ systems for at least a short time.
I'm also trying to find out what tax U.S companies avoid paying to the >>>>U.S. Govt by moving their headquarters to Ireland. As far as I can >>>>see, they avoid paying the U.S tax on their foreign earnings - is
that correct? If so, why should the U.S Govt get a share of the
profit made in a foreign country?
Broadly I think you are correct - the US company becomes a subsidiary
of a global company. A US company is however required to pay tax on
total worldwide income, presumably with some recognition for taxes
paid outside the USA.
where they operate based on the profit in that company, it is not accumulated >>back home.
Oh,Thanks! Was I describing the situation for individuals?
All I know about that is that it is very
complicated! - and some nominally US companies pay little tax in New >>>Zealand (Google and Apple have had the most publicity).
Also, when determining the profit made in a foreign country, how much >>>>of research and development costs are you allowed to claim as part of >>>>the cost of making the product?
Tony
Rich80105<rich80105@hotmail.com> wrote:
On Sun, 07 Feb 2016 22:19:23 -0600, Tony <lizandtony at orcon dot netI don't know what you were describing but it was patently wrong!
dot nz> wrote:
Rich80105<rich80105@hotmail.com> wrote:
On Mon, 08 Feb 2016 11:32:08 +1300, nospam <nospam@nospam.nospam> >>>>wrote:I believe that is completelly incorrect. A US company pays tax in the >>>countries
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com> >>>>>wrote:As far as I am aware the profits in Australia that count for
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net >>>>>>dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>>>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are >>>>>>>liable)
Or what about rental property owned by foreigners. Do they pay any >>>>>>>>tax to the NZ Govt?
but
foreign companies operating in New Zealand are liable to pay tax here at >>>>>>>the
same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a >>>>>>>maximum
price that a company can charge its overseas susidiaries. This protects >>>>>>>the
home base country against transferring tax burdens overseas. NZ may have >>>>>>>this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New >>>>>>Zealand taxable income, which depending on your view, may or may not >>>>>>be the same as "nospam" meant by "the money it earns". During the term >>>>>>of the last Labour Government rules were changed so that banks now >>>>>>have to maintain funds in New Zealand to cover prudential reserves for >>>>>>their New Zealand operations, and I think they also have to maintain >>>>>>systems to enable the banks to keep operating if they ar cut off from >>>>>>their head offices overseas. That has limited the scope for outrageous >>>>>>charging os NZ branches / subsidiaries (transfer pricing) to shift >>>>>>profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any >>>>>>event. That may not be the case with all companies - Google has hit >>>>>>the news internationally (they are making 'voluntary"tax payments to >>>>>>various governments), and in New Zealand Apple have made the news for >>>>>>the low taxes that they pay - in effect they buy product for sale at >>>>>>just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords - >>>>>>just as fo many domestic landlords they may be able to defer tax on >>>>>>propoerties for a long period, especially if they control borrowing >>>>>>and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>>>>>possible", and probably less than New Zealand owners as they have >>>>>>greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax to >>>>>the Australian Govt on the profit it makes in New Zealand?
Australian tax liability would be after payment of New Zealand taxes - >>>>they would make profit from two main areas. First any dividends paid
by the New Zealand operations (for Westpac I suspect that is a New >>>>Zealand company) - they would be treated as for any other New Zealand >>>>dividends for Australian tax. Then there is interest received on any >>>>lending from Austrralian Westpac to NZ Westpac, and charges for other >>>>services. Again they are subject to Australian tax, but may be >>>>deductible for New Zealand tax. I am not an expert on international >>>>taxes though, but I do now that there were investigations some years >>>>ago into whether Australian parent banks were charging fairly for >>>>services provided - NZ banks are now required to be able to operate >>>>with domestic NZ systems for at least a short time.
I'm also trying to find out what tax U.S companies avoid paying to the >>>>>U.S. Govt by moving their headquarters to Ireland. As far as I can >>>>>see, they avoid paying the U.S tax on their foreign earnings - is >>>>>that correct? If so, why should the U.S Govt get a share of the >>>>>profit made in a foreign country?
Broadly I think you are correct - the US company becomes a subsidiary >>>>of a global company. A US company is however required to pay tax on >>>>total worldwide income, presumably with some recognition for taxes
paid outside the USA.
where they operate based on the profit in that company, it is not accumulated
back home.
Oh,Thanks! Was I describing the situation for individuals?
All I know about that is that it is very
complicated! - and some nominally US companies pay little tax in New >>>>Zealand (Google and Apple have had the most publicity).
Also, when determining the profit made in a foreign country, how much >>>>>of research and development costs are you allowed to claim as part of >>>>>the cost of making the product?
Tony
Tony
On Sun, 07 Feb 2016 22:49:11 -0600, Tony <lizandtony at orcon dot netUS company 'net' tax does not include tax paid overseas - your quote makes that clear. It is effectively a double tax agreement.
dot nz> wrote:
Rich80105<rich80105@hotmail.com> wrote:
On Sun, 07 Feb 2016 22:19:23 -0600, Tony <lizandtony at orcon dot netI don't know what you were describing but it was patently wrong!
dot nz> wrote:
Rich80105<rich80105@hotmail.com> wrote:
On Mon, 08 Feb 2016 11:32:08 +1300, nospam <nospam@nospam.nospam> >>>>>wrote:I believe that is completelly incorrect. A US company pays tax in the >>>>countries
On Sat, 30 Jan 2016 17:14:23 +1300, Rich80105<rich80105@hotmail.com> >>>>>>wrote:As far as I am aware the profits in Australia that count for >>>>>Australian tax liability would be after payment of New Zealand taxes - >>>>>they would make profit from two main areas. First any dividends paid >>>>>by the New Zealand operations (for Westpac I suspect that is a New >>>>>Zealand company) - they would be treated as for any other New Zealand >>>>>dividends for Australian tax. Then there is interest received on any >>>>>lending from Austrralian Westpac to NZ Westpac, and charges for other >>>>>services. Again they are subject to Australian tax, but may be >>>>>deductible for New Zealand tax. I am not an expert on international >>>>>taxes though, but I do now that there were investigations some years >>>>>ago into whether Australian parent banks were charging fairly for >>>>>services provided - NZ banks are now required to be able to operate >>>>>with domestic NZ systems for at least a short time.
On Fri, 29 Jan 2016 20:43:24 -0600, Tony <lizandtony at orcon dot net >>>>>>>dot nz> wrote:
nospam <nospam@nospam.nospam> wrote:
Does a company such as Australian owned Westpac, pay tax on the money >>>>>>>>>it earns in NZ to the NZ Govt or to the Australian Govt?Not sure about non-resident landlords (although I suspect they are >>>>>>>>liable)
Or what about rental property owned by foreigners. Do they pay any >>>>>>>>>tax to the NZ Govt?
but
foreign companies operating in New Zealand are liable to pay tax here >>>>>>>>at
the
same rate as a New Zealand based company.
Many countries have arms length requirements for tax which enforce a >>>>>>>>maximum
price that a company can charge its overseas susidiaries. This protects >>>>>>>>the
home base country against transferring tax burdens overseas. NZ may >>>>>>>>have
this
requirement but I don't know..
Tony
Westpac (and other foreign owned companies) will pay tax on New >>>>>>>Zealand taxable income, which depending on your view, may or may not >>>>>>>be the same as "nospam" meant by "the money it earns". During the term >>>>>>>of the last Labour Government rules were changed so that banks now >>>>>>>have to maintain funds in New Zealand to cover prudential reserves for >>>>>>>their New Zealand operations, and I think they also have to maintain >>>>>>>systems to enable the banks to keep operating if they ar cut off from >>>>>>>their head offices overseas. That has limited the scope for outrageous >>>>>>>charging os NZ branches / subsidiaries (transfer pricing) to shift >>>>>>>profit from one country to another.
Arbitrage between Australia and New zealand is fairly low in any >>>>>>>event. That may not be the case with all companies - Google has hit >>>>>>>the news internationally (they are making 'voluntary"tax payments to >>>>>>>various governments), and in New Zealand Apple have made the news for >>>>>>>the low taxes that they pay - in effect they buy product for sale at >>>>>>>just enough to cover costs in New Zealand.
I would be interested in the situation for non-resident landlords - >>>>>>>just as fo many domestic landlords they may be able to defer tax on >>>>>>>propoerties for a long period, especially if they control borrowing >>>>>>>and are able to move profits that way.
I suspect the answer to the question in the subject is äs little as >>>>>>>possible", and probably less than New Zealand owners as they have >>>>>>>greater ability to show only one side of some transactions.
Thanks for the reply. Do you know whether Westpac also pays tax to >>>>>>the Australian Govt on the profit it makes in New Zealand?
I'm also trying to find out what tax U.S companies avoid paying to the >>>>>>U.S. Govt by moving their headquarters to Ireland. As far as I can >>>>>>see, they avoid paying the U.S tax on their foreign earnings - is >>>>>>that correct? If so, why should the U.S Govt get a share of the >>>>>>profit made in a foreign country?
Broadly I think you are correct - the US company becomes a subsidiary >>>>>of a global company. A US company is however required to pay tax on >>>>>total worldwide income, presumably with some recognition for taxes >>>>>paid outside the USA.
where they operate based on the profit in that company, it is not >>>>accumulated
back home.
Oh,Thanks! Was I describing the situation for individuals?
All I know about that is that it is very
complicated! - and some nominally US companies pay little tax in New >>>>>Zealand (Google and Apple have had the most publicity).
Also, when determining the profit made in a foreign country, how much >>>>>>of research and development costs are you allowed to claim as part of >>>>>>the cost of making the product?
Tony
Tony
Well actually Rich was correct. >http://www.bloomberg.com/news/articles/2015-07-22/tim-cook-s-181-billion-headache-apple-s-cash-held-overseas
<Quote>
Under current law, U.S. companies owe the full 35 percent corporate
tax rate -- the highest of any industrialized nation - - on income
they earn around the world. They receive tax credits for payments to
foreign governments, and have to pay the U.S. the difference only when
they bring the money home.
</>
This is why many U.S. companies have moved their headquarters to
Ireland where the tax rate is much lower.
NZ has a "double tax" agreement with many countries both to ensure
that NZ companies aren't taxed twice and to prevent companies from
avoiding tax.
http://www.ird.govt.nz/international/residency/dta/#dtahas
I think NZ should be going after Apple for back taxes like Australia
is.
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