The Relationship between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties: A New Zealand Case

Journal
International; New Zealand; OECD
Bulletin for International Taxation 2018 (Volume 72), No. 7
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.