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Protocol Amending the Agreement between the Government of New Zealand and the Government of the Cook Islands for the Allocation of Taxing Rights with Respect to Certain Income of Individuals and to Establish a Mutual Agreement Procedure in Respect of Transfer Pricing Adjustments done at Rarotonga, Cook Islands on 9 July, 2009
Treaty Type:
Bilateral/Plurilateral
Common Name:
Responsible Department:
Inland Revenue
Administering Department:
Inland Revenue
Treaty Summary:
The aim is to conclude an amending Protocol to New Zealand's 2009 Supplementary Agreement to the Tax Information Exchange Agreement (TIEA) with the Cook Islands. The purpose of the Protocol is to incorporate the mimimum standards and some best practice treaty provisions resulting from the OECD's base erosion and profit shifting (BEPS) project into the Supplementary Agreement.
NZ Adherence Status:
In Progress
Negotiation Status:
Negotiation of the Protocol was concluded in September 2023. Both New Zealand and the Cook Islands will work through their respective domestic procedures for signing and entry into force of the Protocol. Once these are complete, the Protocol will enter into force following an exchange of diplomatic notes.
Organisation:
Is Signed By NZ:
No
Signature Date:
Ratified or Signed:
No
Requires Ratification:
No
NZ Territorial Applications:
None
Information about required Legislation:
An Order in Council, made under section BH 1 of the Income Tax Act 2007, will be required to give effect to the Protocol under New Zealand law.
Impacts on Maori:
The scope of this TIEA is such that there will be no specific impact on Māori.
Impacts on Stakeholders:
Not applicable.
Link To Legislation:
Treaty Text Link:
Contact Information:
If you would like more information about this Treaty please contact us using our contact form.