High Court Quashes Inland Revenue’s Request for Information Notices Following Information Request from Korea

This case note canvasses the reasons underlying the decision of the High Court to quash request for information notices issued by the New Zealand Inland Revenue Department to obtain information from a tax agent in order to satisfy a request by the Korean National Tax Service under article 25 (Exchange of Information) of the Korea-New Zealand Income Tax Treaty (1981). In particular, the Court addressed the extent that the competent authority enquired into the necessity for the information and admonished the Commissioner of Inland Revenue for her failure to disclose vital documents to the Court.