Description
Attend and earn 1 CPD hour
* This interactive online recording includes questions and quizzes requiring critical thinking about the topics, so you have no annual limits to the number of points/hours you can claim with this format of learning. Please verify with your CPD rules
Chair
James Coleman, Barrister, Capital Chambers
Tax-Related Considerations of Debt Issuances, Remissions, Assignments, and Restructures
- Non-resident withholding tax (NRWT) and non-resident financial arrangement income (NRFAI): What is it and when does it apply?
- Approved Issuer Levy (AIL) regime: recent legislative changes and its application to debt issuances
- RWT on loan agreements: When does it apply, and when does it not apply?
- Tax issues with shareholder current accounts and how they are treated on the sale of businesses or shares
- Considerations around debt forgiveness in a corporate context: When is it appropriate and when is it not?
Presented by David Johnston, Partner, DLA Piper
Learning Objectives:
- Understand tax implications of debt transactions including NRWT, AIL, and shareholder current accounts
- Learn when debt forgiveness is tax-effective and how restructuring impacts tax obligations
Presenters
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.
David Johnston, Partner, DLA Piper
David has over 22 years of tax experience and leads DLA Piper's New Zealand tax team. David's particular areas of expertise include providing tax advice on M&A transactions, restructurings, inbound and outbound investment and tax disputes with the Inland Revenue. David is ranked as a leading individual in Legal 500, ranked in International Tax Review (ITR) and ranked by Chambers Asia-Pacific 2025. David has broad industry exposure and provides tax advice to clients in a number of different sectors, including banking, asset management, insurance and technology. David is also a member of the Law Society Tax Committee and the Financial Services Council (FSC) Tax Committee.
