Income and Land Tax Reforms and Tax Driven Property Investment Structures

With recent amendments to bright-line, income and land tax, failing to stay informed could leave you vulnerable to costly mistakes and missed opportunities for you and your clients. Invest in your own knowledge as you explore recent legislative amendments impacting residential and commercial land and unravel the complexities of land banking tax matters. Discover optimal structures for land investments and arm yourself with invaluable insights to maximise returns.

Thursday, 8 August 2024
2.45pm to 3.30pm The New Bright-Line Property Tax Changes


  • The operation of the new two-year bright-line rule
  • What the new rule means for properties acquired under the previous ten-year and five-year rules
  • An explanation of the expanded bright-line “rollover relief” provisions
  • An overview of the re-introduction of interest deductibility for residential investment property

Presented by Bruce Bernacchi, Partner, Dentons

3.30pm to 3.45pm Break
3.45pm to 4.30pm Overseas Investment Act Update


  • Recent and upcoming changes in practice
  • The key duties that property lawyers owe to their overseas clients
  • Common issues, mistakes and causes of delay involving overseas investors, and how to avoid them

Presented by Pedro Morgan, Overseas Investment Lead, Land Information New Zealand

Learning Objectives:
  • Consider recent tax amendments under the coalition government for residential and commercial land  
  • Receive a detailed breakdown of recent changes to bright-line tax  
  • Benefit from a breakdown of key property joint investment structuring vehicles

Attend and earn 3 CPD hours


James Coleman, Barrister, Capital Chambers

2.00pm to 2.45pm Income Tax and Land Tax: Recent Amendments

Land tax rules in the Income Tax Act 2007 and recent issues, including:

  • Recent legislative amendments under the coalition government for residential and commercial land
  • Issues arising for farmland sales
  • Land banking tax issues
  • Structures for land investments

Presented by Simon Akozu, Partner, MinterEllisonRuddWatts, and Phillip Chrisp, Senior Associate, MinterEllisonRuddWatts

4.30pm to 5.15pm Structuring Joint Property Investment


  • different investment vehicles (including company, partnership or unincorporated joint venture)
  • Association rules
  • Exit considerations
  • Other key structuring risks and how to manage them through documentation

Presented by Chris Harker, Partner, Mayne Wetherell


James Coleman, Barrister, Capital Chambers
James is a specialist tax barrister practicing in Wellington. He has over 20 year experience in tax litigation and has appeared many times in the Privy Council, Supreme Court and Court of Appeal. He is the author of tax avoidance law in New Zealand and teaches a unit at the University of Auckland taxation master's programme.

Pedro Morgan, Overseas Investment Lead, Land Information New Zealand
Pedro is Toitū Te Whenua Land Information New Zealand’s overseas investment lead. He has been working within the overseas investment regime since 2004 in range of enforcement, policy, legal and leadership roles. He regularly presents on topics connected with the regulation of investment.

Chris Harker, Partner,Mayne Wetherell
Chris advises on tax law. He has advised on a number of significant transactions including mergers and acquisitions, restructures, Public Private Partnerships (PPPs), and financing arrangements. He has also acted for clients seeking binding rulings from Inland Revenue in respect of prospective transactions, and represented clients in respect of Inland Revenue investigations and disputes.

Bruce Bernacchi, Partner, Dentons
Bruce leads the Dentons Tax team. He has over 27 years’ experience advising on a wide range of taxation issues, including domestic and international corporate tax matters, indirect taxes, and employee tax issues. Bruce has advised on buy-side and sell-side M&A transactions for domestic and offshore clients transacting in New Zealand. He is an expert in undertaking purchaser tax due diligence, vendor tax due diligence, reviewing sale and purchase agreements, advising on transaction structuring and leading post-acquisition tax integration activities. Bruce specialises in advising private equity clients, the financial services sector, technology companies and Iwi tax matters. He is also a specialist in advising on in-bound investment into New Zealand by foreign companies and in advising New Zealand businesses expanding offshore. He has extensive experience in advising on inbound investment from, and outbound investment into, the United States, Australia, and many countries across Asia Pacific. Bruce is an experienced and pragmatic tax adviser who brings a strong mix of technical skills, commercial acumen, and a focus on explaining complex tax issues to clients in a clear and straightforward manner. He is also a regular media commentator on topical New Zealand tax issues, appearing on television, radio and in print media.

Simon Akozu, Partner, MinterEllison RuddWatts
Simon is a tax specialist, focused on mergers and acquisitions (M&A), infrastructure projects, financing arrangements, and crypto assets. Simon has broad experience managing tax projects across a wide range of industries. His clients include leading New Zealand corporates, multinationals, financial institutions, and high net worth individuals. Simon is also working with a range of start-ups in the crypto asset space. Simon has a keen interest in tax policy. He regularly writes and presents on new developments in tax, including the taxation of crypto assets. He is a contributor to Bloomberg Tax and is a co-author of Bloomberg’s New Zealand country guide.

Phillip Chrisp, Senior Associate, MinterEllisonRuddWatts
Phillip is a tax law specialist with broad experience advising on New Zealand tax matters. Phillip has a particular focus on corporate taxation, regularly advising on the tax aspects of business and property transactions. He has four years’ Big Four experience in transfer pricing and has a particular interest in advising clients on structuring, international taxation and financing. He also routinely assists businesses with tax controversies and disputes and obtaining rulings. He also advises on commercial contracts, employment taxation, regulatory tax compliance (including FATCA/CRS) and GST. Phillip’s key clients include a number of New Zealand listed clients and leading businesses, large multinational enterprises, private equity and managed funds, warranty and indemnity insurers, and high net worth individuals. Phillip’s approach is to provide clear, thoughtful and client-focused advice. His ability to put himself in the shoes of clients to understand their objectives and to identify key risks and value drivers to reach commercial outcomes, leads to Phillip establishing enduring relationships with clients and becoming a trusted adviser.


Income and Land Tax Reforms and Tax Driven Property Investment Structures


Single Session
Thursday, 8 August 2024
2.00pm to 5.15pm New Zealand
CPD Hours 3
Online 20240615 20240808


On Demand 20240615 20240808

Post Seminar Recording