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Very good, they understand TP requirements well enough
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They do not understand the requirements of the TP department
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Alesco tax avoidance held

January 03, 2012

The decision on intercompany debt funding has been made by the New Zealand High Court in Alesco New Zealand Ltd v CIR.

The case involved one of 16 taxpayers for whom court proceedings have been filed against the Commissioner of Inland Revenue’s assessments, which disallowed certain deductions arising from the movement of optional convertible note (OCN) instruments between related parties.

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