The Resource Key issues in the design of capital gains tax regimes : taxing non-residents

Key issues in the design of capital gains tax regimes : taxing non-residents

Label
Key issues in the design of capital gains tax regimes : taxing non-residents
Title
Key issues in the design of capital gains tax regimes : taxing non-residents
Creator
Subject
Language
eng
Summary
This article examines two broad areas of capital gains tax (CGT) design in respect of the taxaton of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by non-residents or to some limited subset of those assets (including the possibility of it not applying it at all.) The second area is how New Zealand double tax agreements (DTAs) interact with or change domestic CGT taxing rights. After examining those two broad areas, the author considers what New Zealand's policy should be in respect of determining how we tax movable property where the gain is situated in New Zealand. The author includes by examining some areas of concern that can arise where there are significant differences in taxation for residents of different countries because of the different allocation of taxing rights in DTAs. These areas include treaty shopping and the avoidance possibilities that will occur unless there is a consistent taxing policy applied in New Zealand's DTA network
Citation source
In: New Zealand journal of taxation law and policy. - Wellington. - Vol. 21 (2015),
http://library.link/vocab/creatorName
Elliffe, C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • capital gains tax
  • non-resident
  • tax treaty
  • treaty shopping
  • anti-avoidance
Label
Key issues in the design of capital gains tax regimes : taxing non-residents
Instantiates
Publication
Label
Key issues in the design of capital gains tax regimes : taxing non-residents
Publication

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