Globalisation and tax administration - a New Zealand perspective

The work of the G20 and OECD in relation to Base Erosion and Profit Shifting (BEPS) 1.0, and more recently with BEPS 2.0, has shown unprecedented levels of cooperation between revenue authorities globally. While the work to date has increased the sharing of information and improved cooperation on cross-border investigations, it has also led to enhancements (some currently at the policy refinement stage) that expand the tax base (such as new taxing rights for jurisdictions where value has been added), and buttress existing core tax concepts (such as residence and source). This article, taking the form of a case study, examines and reflects upon how these policy developments are impacting revenue authorities, with a focus on New Zealand. It traverses the administrative direction and political influences over the last six to eight years, within the wider context of Inland Revenue's Business Transformation project (BT) that was completed in 2022. Digitalisation has been critical to the way Inland Revenue has navigated the challenges it faces, many of which are common to tax administrations globally. In general terms, New Zealand is a 'strong supporter' of the work of the G20/OECD with respect to BEPS but would not be considered to be a leader. Being a small jurisdiction, New Zealand is less impacted by BEPS issues, but nevertheless it faces its fair share of administrative challenges, including the ongoing impact of COVID fiscal reforms on tax administrations.