Protocol between the Government of the Isle of Man and the Government of New Zealand Amending the Agreement of 27 July 2009 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

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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 Isle of Man. The purpose of the Protocol is to incorporate the minimum 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 July 2024. Both New Zealand and the Isle of Man 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:

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