Hon Dr Michael Cullen Minister of Revenue
21 September 2004
New tax rules for foreign owned banks
The Government will introduce legislation to ensure foreign-owned banks operating in New Zealand pay enough tax on their
New Zealand income, Revenue Minister Michael Cullen announced today.
“The New Zealand tax payments of foreign-owned banks have not appeared to reflect their reported profits in recent
times,” Dr Cullen said. “I am advised that they are using certain features of our tax rules to pay less tax in New
Zealand.”
“The legislative change should result in these banks paying around $360 million more a year in New Zealand tax,” Dr
Cullen said.
For tax purposes, new rules specific to banks will deny them interest deductions if they do not hold a level of capital
equivalent to four percent of their New Zealand banking assets, weighted for risk.
“If banks want full interest deductions for tax purposes, they will also be required to have enough capital in New
Zealand to fully fund their offshore investments,” Dr Cullen explained.
Once the legislation is enacted, the situation will be monitored carefully to ensure that banks pay a level of tax
appropriate to their New Zealand-sourced income and their worldwide operations.
The Government has consulted with the banking industry on the development of these proposals, with the result that many
of the industry’s concerns about the new legislation have been addressed. The legislation will be included in a taxation
bill to be introduced in November.
ENDS