New Zealand Tax Agency Seeks Comments on Land Development Income Taxation for Portfolio Investment Entities

The New Zealand Inland Revenue March 5 opened a consultation on Exposure Draft No. PUB00508, proposed guidance to clarify whether income from developing land is eligible income under Income Tax Act 2007 for portfolio investment entity (PIEs). The proposed guidance would clarify that: 1) a qualifying PIE must have at least 90 percent of its investments be from land interests, financial arrangements, excluded financial arrangements, or related rights or options, and at least 90 percent of its income be from specified sources, including these four sources; 2) the Commissioner interprets the Act’s provision listing these four sources among the types ...