New Zealand Taxpayer Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company

Journal
New Zealand
Asia-Pacific Tax Bulletin 2017 (Volume 23), No. 4
This note summarizes the New Zealand High Court decision in Lin v. Commissioner of Inland Revenue, which entitled a New Zealand-resident taxpayer with relevant interests in certain controlled foreign companies in China to a foreign tax credit for both tax paid in China by the controlled foreign companies and to tax spared in China arising from tax concessions granted to those companies.