CA ANZ takes a strategic approach to its public interest tax advocacy. We engage constructively with IR, government and other tax stakeholders to ensure that tax legislation and pronouncements are well thought out, practical and workable. We focus on areas where we can make a difference and, often by necessity, take a long-term view in our efforts to effect change.

We advocate in the public interest: what is considered best for New Zealand and the tax system. That said, we will often apply a taxpayer/business lens to provide balance and a commercial perspective. This is critical, as proposed tax changes often fail to consider how businesses operate in practice and the likely impact on them.

Prospective tax changes should not detrimentally impact compliant taxpayers and their normal commercial operations. There appears to be a natural tendency for overreach and we will often recommend that a more targeted approach be considered.

The tax advocacy process

The starting point for us is the problem definition (the perceived mischief that is to be addressed) and whether there is sufficient evidence that this is, in fact, an issue. We typically favour use of existing and targeted provisions where possible, before further measures are introduced.

To achieve change, it’s important that we are fully involved in the collaborative tax consultation process. And, we disagree with IR and government where there are divergent views. Recent examples include our position taken on:

• Trust disclosure rules and the trustee tax rate with respect to small trusts
• Charities and not-for-profits
• Dividend integrity measures
• Limitations of the Foreign Investment Fund Revenue Account Method (FIF RAM)
• The need for better fiscal measures and estimates to enable taxpayer-friendly remedials to proceed, when subject to fiscal constraints.

We have also pushed hard to obtain a suite of adverse events measures and a publicly searchable register of remedials items. Interestingly, there is a high correlation between the above examples and the advocacy wins that we are most proud of.

By the numbers

CA ANZ is a unique stakeholder in the tax system in that we submit on virtually all IR, Treasury and government tax consultation items. Each year we file approximately 60 tax submissions, covering a wide range of tax issues from IR Public Ruling items through to policy issues papers, Treasury and IR Long-term Insights Briefings (LTIBs) and tax legislation – with at least one annual tax bill.

Written submissions are often followed up with discussions and, with reference to the tax bill, appearances before parliament’s Finance and Expenditure Committee, engagement with ministers, MPs, and senior IR and Treasury officials.

Our advocacy work is undertaken in conjunction with the CA ANZ Tax Advisory Group: a cross-section of members in public practice, commerce and academia. We welcome member comment on all open public submission items and encourage you to contribute. We publish all our public submissions on the CA ANZ website.

On-going tax advocacy

Our current areas of focus include:

• Tax base sustainability, given changing demographics and future revenue requirements
• Tax compliance cost reduction and a simplified FBT regime
• Reimagined tax administration in a digital world
• Broader tax reform to encourage greater investment into New Zealand productive infrastructure and business
• Fiscal costing framework and estimates overhaul for meaningful tax reform.

A long-term approach to advocacy is often needed. For example, the sustainability of the tax base to meet future government revenue needs is a medium-term issue with various solutions. In this instance, we see our role as an enabler: to socialise the issues and advance informed discussion.

Other advocacy areas are more immediate. CA ANZ has advocated for a simplified FBT and we are hopeful this reform will progress this year. CA ANZ has also long advocated for tax compliance cost reduction measures, and various threshold and simplification measures have been introduced over recent years.