Changes to the interest limitation rules - 15 March 2018 (On Demand)


Draft legislation has been introduced to limit the use of debt financing as a means to “shift profits out of New Zealand”, as part of the Government’s wider BEPS tax reform package.

A key change will be a new transfer pricing rule that will restrict the deductible interest rate that can be applied on many cross border loans into New Zealand. These are fairly complex rules that will apply to existing as well as new loans as early as 1 July 2018. These rules are intended to also apply to cross border guarantee arrangements.

Changes to the thin capitalization rules will require companies to ensure that they will not breach the safe harbour threshold.

This webinar will:

  • Go through the proposed new interest restriction rules and amendments to the thin capitalization rules 
  • Highlight areas that may risk a company forgoing interest deductions 
  • Illustrate with examples 
  • Outline what you need to do in preparation for these law changes 
  • Cover cross border guarantees 
  • Remind about changes already made to non-resident withholding tax rules. 
  • (the proposed changes on hybrid mismatches will be mentioned, but not covered in any detail)


  • Appreciation of the proposed tax changes to impact deductibility of financial arrangements
  • Understand whether thin capitalization changes will impact your company
  • Get insight as to what you could do to mitigate these risks and by when


15 March 2018


This seminar is intended for those involved in a finance or tax role where cross border financial arrangements exist or the entity is otherwise subject to thin capitalization restrictions. This includes practitioners who advise such clients. A high level of expertise on financing arrangements or knowledge of transfer pricing is not a pre-requisite.


Mark Loveday, International tax/transfer pricing partner, EY

1.15 CPD hours

  • On Demand Event
    Complete online in your own time (Self-paced)
    • $180.00 excl. GST

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Sole practitioners

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