Tax Scorecard

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Match 1AUSTRALIA
NEW ZEALAND
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Currency and Rate / $

Australian Dollar (AUD) AUD / USD = 1.29

New Zealand Dollar (NZD) NZD / USD = 1.32

Tax Year

30 June 

1 April to 31 March 

RoI Filing Due Date

15 January for corporates, 31 October for individuals 

31 March the year following balance date with the exception of companies with 31 October to 31 December balance date, in which case the due date is 31 March subsequent to following year. These filing dates apply provided the company is linked to a 'tax agent'. If not linked to a tax agent, returns are due by 7 June following balance date, or 7th day of 4th month following balance date for April to September balance dates. 

Residential Status
- Individuals

Person residing in Australia and includes who meets either one of the following conditions : he or she is domiciled in Australia unless the tax authority is satisified that the person's permanent place of abode is outside Australia , he or she is present in Australia continuously or intermittently for more than half of the tax year unless the tax authority is satisified that the person's usual place of abode is outside Australia and that the person does not intend to reside in Australia. 

An individual is a resident in New Zealand if

- he has a permanent place of abode in New Zealand, regardless of whether he also has a permanent place of abode in another country; or

- he is present in New Zealand for more than 183 days in any 12-month period. Residence begins with the first day of such a period of presence in New Zealand. 

- Corporates

Corporations incorprated in Australia ; corporations carrying on business in Australia with either their central management and control in Australia or their voting power controlled by Australian residents 

A company is considered to be resident if it is incorporated under New Zealand law. Companies incorporated under foreign law are considered to be resident if they are effectively managed from New Zealand. Resident companies are taxed on their worldwide income. Non-resident companies are taxed only on their New Zealand sourced income. 

Tax Rates
- Individuals

Progressive rates from 0% to 45% 

10.5% (first NZD 14000)

17.5% (NZD 14001 to 48000)

30% (NZD 48001 to 70000)

33% (NZD 70000 and above) 

- Corporates

30% 

28% 

Withholding Tax Rates
- Royalty

30% 

15%

- Fees for Technical Services

0% 

N/A

- Dividends

30% 

Typically, 15% (fully imputed dividends, fully dividend withholding payment credited dividends, supplementary dividends, investment society dividends);

0% (non-cash dividends);

30% (all other dividends) 

- Interest

10% 

15% (if paid to non-associated persons) 

OECD Status

Member 

Member

No. of Treaties

50 

37

Treaty with India

Yes 

Yes

Advance Ruling

Yes, Rulings may be obtained on a broad range of tax issues relating to income tax, Medicare levy, fringe benefits tax, withholding tax, GST, luxury car tax, excise duty and the administration and/or collection of taxes 

Yes. New Zealand Inland Revenue issues both binding and non-binding rulings on tax issues. Binding rulings can be either public or private rulings. 

GAAR

The general income tax antiavoidance regime plays an important role in complementing specific antiavoidance rules. Applies when it is determined that the dominant purpose of the parties entering into a scheme was to enable the taxpayer to obtain a tax benefit; the tax benefit may be denied and significant penalties may be imposed. The amendments apply with respect to schemes entered into on or after 16 November 2012. 

Mix of general and specific anti-avoidance rules. Under the general anti-avoidance rules, transactions are void if they the purpose and intention of New Zealand's tax laws (i.e. have more than incidental purpose or effect of tax avoidance). 

CFC Legislation

A foreign company is a CFC if five or fewer Australian residents hold at least 50% of the company or have de facto control of it, or if a single Australian entity holds a 40% interest in the company, unless it is established that actual control does not exist. The tainted income of a CFC is attributed to its Australian resident owners, which are required to include such income in their assessable income. Whether an amount earned by a CFC is attributable to Australian residents depends on the country in which the CFC is resident. The CFC rules identify “listed countries,” which have tax systems that are considered to be closely comparable to the Australian system. All other countries are “unlisted countries.” Certain amounts are unconditionally attributed regardless of whether the CFC is resident in a listed or unlisted country. If a CFC resident in a listed country fails the active-income test, its attributable income includes “adjusted tainted income,” which is eligible designated concession income prescribed by the regulations on a country-by-country basis. 

Yes. There is no requirement to attribute income of a foreign subsidiary unless the CFC derives more than 5% of its income from "passive" sources (eg. income in the form of dividends, interest, royalties and rents). The passive income must be returned to New Zealand. 

Anti-Tax Haven

Yes, specific anti abuse rules exist such as direct and indirect value shifting rules , round robin transactions which deal with restricting deductions that are in excess of net expenditure incurred by taxpayer and their associates, streaming of dividend and capital benefits 

N/A 

Transfer Pricing

Yes

Yes. Comprehensive transfer pricing regime based on OECD Transfer Pricing Guidelines and the 'arm's length' principle. 

Safe Harbour

Yes

N/A 

APA

Yes

Yes 

Indirect transfer taxation

Yes

N/A

Indirect Tax Regime

GST

GST

- Applicable Rate

10%

15% (Standard), 0% (reduced) 

Match 2INDIA
AUSTRALIA
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Currency and Rate / $

Indian Rupee (INR) INR / USD = 62.38

Australian Dollar (AUD) AUD / USD = 1.27

Tax Year

1 April to 31 March 

30 June 

RoI Filing Due Date

31 July (Individual)

30 November (if Co. has international transaction)

30 September (any other Co.) 

15 January for corporates, 31 October for individuals 

Residential Status
- Individuals

An individual is resident if :

- present in India for a period of 182 days or more in the financial year;

- in India for 60 days or more during the financial year and has been in India for 365 days or more during previous 4 years immediately preceding the relevant financial year 

Person residing in Australia and includes who meets either one of the following conditions : he or she is domiciled in Australia unless the tax authority is satisified that the person's permanent place of abode is outside Australia , he or she is present in Australia continuously or intermittently for more than half of the tax year unless the tax authority is satisified that the person's usual place of abode is outside Australia and that the person does not intend to reside in Australia. 

- Corporates

A Company is considered to be resident in India if it is incorporated in India, or if during any fiscal year (1 April to 31 March), the control and management of its affairs is situated wholly in India. 

Corporations incorprated in Australia ; corporations carrying on business in Australia with either their central management and control in Australia or their voting power controlled by Australian residents 

Tax Rates
- Individuals

Progressive rates;

top tax of Rs 125000 + 30% (excess income over INR 1,000,000) for individuals below 60 years;

top tax of Rs 120000 + 30% (excess income over INR 1,000,000) for individuals between 60 - 80 years;

top tax of Rs 100000 + 30% (excess income over INR 1,000,000) for individuals over 80 years 

Progressive rates from 0% to 45% 

- Corporates

34% 

30% 

Withholding Tax Rates
- Royalty

10% 

30% 

- Fees for Technical Services

10% 

0% 

- Dividends

No, but Indian Co. declaring dividend liable to DDT at 20.47% 

30% 

- Interest

20% 

10% 

OECD Status

Non Member 

Member 

No. of Treaties

96 

50 

Treaty with India

-

Yes 

Advance Ruling

Yes 

Yes, Rulings may be obtained on a broad range of tax issues relating to income tax, Medicare levy, fringe benefits tax, withholding tax, GST, luxury car tax, excise duty and the administration and/or collection of taxes 

GAAR

To be implemented w.e.f. April 2015 

The general income tax antiavoidance regime plays an important role in complementing specific antiavoidance rules. Applies when it is determined that the dominant purpose of the parties entering into a scheme was to enable the taxpayer to obtain a tax benefit; the tax benefit may be denied and significant penalties may be imposed. The amendments apply with respect to schemes entered into
on or after 16 November 2012. 

CFC Legislation

No 

A foreign company is a CFC if five or fewer Australian residents hold at least 50% of the company or have de facto control of it, or if a single Australian entity holds a 40% interest in the company, unless it is established that actual control does not exist. The tainted income of a CFC is attributed to its Australian resident owners, which are required to include such income in their assessable income. Whether an amount earned by a CFC is attributable to Australian residents depends on the country in which the CFC is resident. The CFC rules identify “listed countries,” which have tax systems that are considered to be closely comparable to the Australian system. All other countries are “unlisted countries.” Certain amounts are unconditionally attributed regardless of whether the CFC is resident in a listed or unlisted country. If a CFC resident in a listed country fails the active-income test, its attributable income includes “adjusted tainted income,” which is eligible designated concession income prescribed by the regulations on a country-by-country basis. 

Anti-Tax Haven

N/A

Yes, specific anti abuse rules exist such as direct and indirect value shifting rules , round robin transactions which deal with restricting deductions that are in excess of net expenditure incurred by taxpayer and their associates, streaming of dividend and capital benefits 

Transfer Pricing

Yes 

Yes 

Safe Harbour

Yes 

Yes 

APA

Yes 

Yes 

Indirect transfer taxation

Yes 

Yes 

Indirect Tax Regime

Federal & State 

GST 

- Applicable Rate

12.36% (Service tax)

12.36% (Excise)

0% to 20% (State VAT) 

10% 

Match 3NEW ZEALAND
SOUTH AFRICA
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Currency and Rate / $

New Zealand Dollar (NZD) NZD / USD = 1.32

South African Rand (ZAR) ZAR / USD = 12.04

Tax Year

1 April to 31 March 

Period of 12 months from 1 March of one year to the last day of February of the following year 

RoI Filing Due Date

31 March the year following balance date with the exception of companies with 31 October to 31 December balance date, in which case the due date is 31 March subsequent to following year. These filing dates apply provided the company is linked to a 'tax agent'. If not linked to a tax agent, returns are due by 7 June following balance date, or 7th day of 4th month following balance date for April to September balance dates. 

The Revenue annually gives notice of the categories of persons who are personally or in a representative capacity required to render returns, and specifies the time period within which this must take place. 

Residential Status
- Individuals

An individual is a resident in New Zealand if

- he has a permanent place of abode in New Zealand, regardless of whether he also has a permanent place of abode in another country; or

- he is present in New Zealand for more than 183 days in any 12-month period. Residence begins with the first day of such a period of presence in New Zealand. 

The statutory definition of residence for income tax purposes differentiates between natural persons and any person other than a natural person.

The residence definition for natural persons falls into two parts. A person will be a tax resident if that person is:

- ordinarily resident in South Africa; or

- not ordinarily resident in the current tax year but physically present in South Africa for more than 91 days in the current tax year, physically present for an aggregate of more than 915 days in the preceding 5 tax years and physically present for more than 91 days in each of those preceding 5 tax years. 

- Corporates

A company is considered to be resident if it is incorporated under New Zealand law. Companies incorporated under foreign law are considered to be resident if they are effectively managed from New Zealand. Resident companies are taxed on their worldwide income. Non-resident companies are taxed only on their New Zealand sourced income. 

The statutory definition of residence for income tax purposes differentiates between natural persons and any person other than a natural person. The definition for the latter category falls into two disjunctive parts, to which an overriding exclusion applies:

a resident means any person (other than a natural person) which is

- incorporated, established or formed in South Africa; or - which has its place of effective management in South Africa, but excludes any person who is deemed to be a resident exclusively in another country for purposes of the application of one of South Africa’s tax treaties. 

Tax Rates
- Individuals

10.5% (first NZD 14000)

17.5% (NZD 14001 to 48000)

30% (NZD 48001 to 70000)

33% (NZD 70000 and above) 

Progressive; top bracket 40% (over ZAR 673,100) 

- Corporates

28% 

28% standard rate;

28% top rate for small business companies;

30% long-term insurance (individual; policyholder fund); 33% Republic employment companies;

gold mining: variable 

Withholding Tax Rates
- Royalty

15% 

15% 

- Fees for Technical Services

N/A 

15% 

- Dividends

typically, 15% (fully imputed dividends, fully dividend withholding payment credited dividends, supplementary dividends, investment society dividends);

0% (non-cash dividends);

30% (all other dividends) 

15% 

- Interest

15% (if paid to non-associated persons) 

15% with effect from 1 March 2015 

OECD Status

Member 

Non Member 

No. of Treaties

37 

73 

Treaty with India

Yes 

Yes 

Advance Ruling

Yes. New Zealand Inland Revenue issues both binding and non-binding rulings on tax issues. Binding rulings can be either public or private rulings. 

Yes 

GAAR

Mix of general and specific anti-avoidance rules. Under the general anti-avoidance rules, transactions are void if they the purpose and intention of New Zealand's tax laws (i.e. have more than incidental purpose or effect of tax avoidance). 

South Africa has a statutory general anti-avoidance rule that applies in respect of income tax and capital gains tax, which is augmented by specific reporting obligations in respect of transactions that may ostensibly fall foul of the anti-avoidance rules. 

CFC Legislation

Yes. There is no requirement to attribute income of a foreign subsidiary unless the CFC derives more than 5% of its income from "passive" sources (eg. income in the form of dividends, interest, royalties and rents). The passive income must be returned to New Zealand. 

Yes 

Anti-Tax Haven

N/A

N/A 

Transfer Pricing

Yes. Comprehensive transfer pricing regime based on OECD Transfer Pricing Guidelines and the 'arm's length' principle. 

The new transfer pricing statutory framework effective from 1 January 2013 is no longer discretionary and applies automatically and broader scope for certain categories of transactions. The new rules will require that taxpayers determine the taxable income that would arise from arm’s length transactions and so shift the focus to whether parties to a controlled transaction are obtaining an arm’s length.Thin capitalization is no longer a subset of transfer pricing. 

Safe Harbour

N/A

Yes 

APA

Yes 

N/A

Indirect Tax Regime

GST 

VAT 

- Applicable Rate

15% (Standard), 0% (reduced) 

14% (Standard), 0% (Reduced) 

Match 4NEW ZEALAND
WEST INDIES
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Currency and Rate / $

New Zealand Dollar (NZD) NZD / USD = 1.34

Note : West indies includes different contries like Antigua and Barbuda, Barbados, Dominic, Grenada, Guyana, Jamaica, Saint Lucia, Saint Vincent and the Grenadine,Trinidad and Tobago and other British, Dutch and US dependent countries. Each of the countries have their own tax regime.

For reference purposes, we have provided details of Barbados.

Barbadian Dollar (BBD) BBD / USD = 2.00

Tax Year

1 April to 31 March 

Fiscal Year for Individuals (profits of trade or business) and Corporates Calendar Year for other Individuals 

RoI Filing Due Date

31 March the year following balance date with the exception of companies with 31 October to 31 December balance date, in which case the due date is 31 March sebsequent to following year. These filing dates apply provided the company is linked to a 'tax agent'. If not linked to a tax agent, returns are due by 7 June following balance date, or 7th day of 4th month following balance date for April to September balance dates. 

Individuals - On or before April 30th of the following year.

Corporations whose fiscal year ends during 1 January to 30 September -15 March of the year following the income year. Corporations whose fiscal year ends during 1 October to 31 December - 15 June of the year following the income year. 

Residential Status
- Individuals

An individual is a resident in New Zealand if

- he has a permanent place of abode in New Zealand, regardless of whether he also has a permanent place of abode in another country; or

- he is present in New Zealand for more than 183 days in any 12-month period. Residence begins with the first day of such a period of presence in New Zealand. 

A Resident is a corporation managed and controlled in Barbados; or a non-national individual who is present in Barbados for more than 182 days in a calendar year. A resident corporation is subject to tax on its world income. A resident and domicile individual is subject to tax on his world income. The resident but not domiciled individual is subject to tax on his income derived in Barbados and on his income from foreign sources remitted to Barbados, or from which a benefit is derived in Barbados.
A Non-resident is a corporation whose place of management and control is outside Barbados; or a non-national individual who is present in Barbados for less than 183 days in a calendar year. A non-resident is subject to tax only on income derived in Barbados. 

- Corporates

A company is considered to be resident if it is incorporated under New Zealand law. Companies incorporated under foreign law are considered to be resident if they are effectively managed from New Zealand. Resident companies are taxed on their worldwide income. Non-resident companies are taxed only on their New Zealand sourced income. 

A company is considered to be resident in Barbados if its management and control are located in Barbados. 

Tax Rates
- Individuals

10.5% (first NZD 14000)

17.5% (NZD 14001 to 48000)

30% (NZD 48001 to 70000)

33% (NZD 70000 and above) 

Progressive;

top bracket 35% (over BBD 35,000 taxable income);

separate consolidation tax (0.5%-3%) on gross annual income over BBD 50,000 

- Corporates

28% 

25% 

Withholding Tax Rates
- Royalty

15% 

15% (pre-payment if non-resident company files a tax return) 

- Fees for Technical Services

N/A 

15% (pre-payment if non-resident company files a tax return) 

- Dividends

typically, 15% (fully imputed dividends, fully dividend withholding payment credited dividends, supplementary dividends, investment society dividends);

0% (non-cash dividends);

30% (all other dividends) 

15%;

25% if paid out of profits that are exempt or have not been taxed;

0% if paid out of foreign source income 

- Interest

15% (if paid to non-associated persons) 

15% (pre-payment if non-resident company files a tax return);

0% on government bonds or debentures 

OECD Status

Member 

Non Member 

No. of Treaties

37 

29 

Treaty with India

Yes 

No 

Advance Ruling

Yes. New Zealand Inland Revenue issues both binding and non-binding rulings on tax issues. Binding rulings can be either public or private rulings. 

N/A 

GAAR

Mix of general and specific anti-avoidance rules. Under the general anti-avoidance rules, transactions are void if they the purpose and intention of New Zealand's tax laws (i.e. have more than incidental purpose or effect of tax avoidance). 

Anti-avoidance provisions may be applied to transactions between related persons that are not carried
out at arm’s length and to artificial transactions if the primary purpose of the transaction is the reduction of taxable income. 

CFC Legislation

Yes. There is no requirement to attribute income of a foreign subsidiary unless the CFC derives more than 5% of its income from "passive" sources (eg. income in the form of dividends, interest, royalties and rents). The passive income must be returned to New Zealand. 

N/A

Transfer Pricing

Yes. Comprehensive transfer pricing regime based on OECD Transfer Pricing Guidelines and the 'arm's length' principle.  

No 

APA

Yes 

No 

Indirect Tax Regime

GST 

VAT 

- Applicable Rate

15% (Standard), 0% (reduced) 

17.5% (Standard)

0%, 7.5% (reduced) 

Match 5AUSTRALIA
PAKISTAN
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Currency and Rate / $

Australian Dollar (AUD) AUD / USD = 1.30 

Pakistani Rupee (PKR) PKR/USD = 102.02

Tax Year

30 June 

12 months period ending on 30 June 

RoI Filing Due Date

15 January for corporates, 31 October for individuals 

- For any person (other than a company) must be submitted by 30 September following the end of the tax year to which the return relates;

- For a company the income year of which ends between 1 January and 30 June, 31 December following the income year;

- and for a company the income year of which ends at any date after 30 June, on 30 September 

Residential Status
- Individuals

Person residing in Australia and includes who meets either one of the following conditions : he or she is domiciled in Australia unless the tax authority is satisified that the person's permanent place of abode is outside Australia , he or she is present in Australia continuously or intermittently for more than half of the tax year unless the tax authority is satisified that the person's usual place of abode is outside Australia and that the person does not intend to reside in Australia. 

An individual is resident if :

- present in Pakistan for a period or periods amounting to 183 days or more in the tax year; or

- an employee or official of the federal government or a provincial government posted abroad in the tax year

Residence status is determined with reference to each tax year, and as such, an individual who is resident in one tax year is not automatically resident in the subsequent tax year. 

- Corporates

Corporations incorprated in Australia ; corporations carrying on business in Australia with either their central management and control in Australia or their voting power controlled by Australian residents 

A company is resident in Pakistan for a tax year if:

- it is incorporated or formed by or under any law in force in Pakistan; or

- the control and management of its affairs is situated wholly in Pakistan at any time of the year. A company is resident only from the year control and management is situated in Pakistan. 

Tax Rates
- Individuals

Progressive rates from 0% to 45% 

progressive; top rate 30% (income over PKR 7,000,000) for individuals with salary exceeding 50% of total income; top rate 35% (income over PKR 6,000,000) for others 

- Corporates

30% 

33% standard rate (to be reduced to 30% by a reduction of 1% every year);

35% for banking companies;

25% for small companies;

presumptive tax regime applies in specific cases 

Withholding Tax Rates
- Royalty

30% 

15% 

- Fees for Technical Services

0% 

15% 

- Dividends

30% 

10%;

concessional rate of 7.5% applies to dividends from companies engaged in power generation, privatized power projects, or companies supplying coal exclusively to power generation projects;

12.5% on dividends from stock funds where dividends are less than capital gains; 25% for dividends from non-stock funds 

- Interest

10% 

10% 

OECD Status

Member 

Non Member 

No. of Treaties

50 

63

Treaty with India

Yes 

No 

Advance Ruling

Yes, Rulings may be obtained on a broad range of tax issues relating to income tax, Medicare levy, fringe benefits tax, withholding tax, GST, luxury car tax, excise duty and the administration and/or collection of taxes 

No, except for non-residents 

GAAR

The general income tax antiavoidance regime plays an important role in complementing specific antiavoidance rules. Applies when it is determined that the dominant purpose of the parties entering into a scheme was to enable the taxpayer to obtain a tax benefit; the tax benefit may be denied and significant penalties may be imposed. The amendments apply with respect to schemes entered into
on or after 16 November 2012. 

ITO contains anti-avoidance provisions and also specifies the use of the principle "substance over form" 

CFC Legislation

A foreign company is a CFC if five or fewer Australian residents hold at least 50% of the company or have de facto control of it, or if a single Australian entity holds a 40% interest in the company, unless it is established that actual control does not exist. The tainted income of a CFC is attributed to its Australian resident owners, which are required to include such income in their assessable income. Whether an amount earned by a CFC is attributable to Australian residents depends on the country in which the CFC is resident. The CFC rules identify “listed countries,” which have tax systems that are considered to be closely comparable to the Australian system. All other countries are “unlisted countries.” Certain amounts are unconditionally attributed regardless of whether the CFC is resident in a listed or unlisted country. If a CFC resident in a listed country fails the active-income test, its attributable income includes “adjusted tainted income,” which is eligible designated concession income prescribed by the regulations on a country-by-country basis. 

No 

Anti-Tax Haven

Yes, specific anti abuse rules exist such as direct and indirect value shifting rules , round robin transactions which deal with restricting deductions that are in excess of net expenditure incurred by taxpayer and their associates, streaming of dividend and capital benefits 

N/A

Transfer Pricing

Yes 

ITO contains an international anti-avoidance provision which is very wide in scope. This aims to counter situations where the CIR may, in respect of any transaction between persons who are associates, distribute, apportion or allocate income, deductions or tax credits between the persons as is necessary to reflect the income that the persons would have realized in an arm’s length transaction. 

Safe Harbour

Yes 

N/A 

APA

Yes 

N/A 

Indirect transfer taxation

Yes 

Under the repealed ITO 1979 

Indirect Tax Regime

GST 

Federal 

- Applicable Rate

10% 

16% to 17% (Sales Tax)

10% to 16% (Excise Duty)