The Thin Capitalization Regime – A Discussion of Current and Proposed Rules

The New Zealand tax authorities, in January 2013, released an Issues Paper reviewing the current thin capitalization regime and proposing a number of changes. The proposals contained in the paper are part of the overhaul of New Zealand’s international tax system, which began in 2007. In addition to providing a description of the current system and proposed changes, the authors also analyse the impact the proposed changes will bring about.