[World Tax News] New Zealand Consults on Shareholder Loan Taxation | UAE Issues DMTT Guidance

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  • Last Updated on 15 December, 2025

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New Zealand on Shareholder Loan Taxation

Editorial Team – [2025] 181 taxmann.com 368 (Article)

World Tax News provides a weekly snippet of tax news from around the globe. Here is a glimpse of the tax happening in the world this week:

1. New Zealand Begins Consultation on Taxation of Company to Shareholder Loans

New Zealand Inland Revenue has initiated a public consultation on proposed changes to the taxation framework for loans provided by companies to their shareholders. Submissions are open until 5 February 2026.

Key Proposal

Inland Revenue is seeking feedback on measures aimed at improving the tax treatment of new shareholder loans. The central proposal introduces a new time-limit rule, under which certain loans made by a company to its shareholders would be treated as dividends if they are not repaid within 12 months from the end of the income year in which they were issued.

This rule would:

  • Apply only to new loans, excluding all existing shareholder loans; and
  • Apply only where a company’s total lending to shareholders is NZD 50,000 or more.

Further Information

Additional details are available in the following materials:

  • Officials’ issues paper: Improving taxation of loans made by companies to shareholders
  • Information sheet: Improving taxation of loans made by companies to shareholders
  • Inland Revenue media release

Source – Public Consultation

2. Hong Kong Updates List of Qualifying Debt Instruments Eligible for Tax Concessions

The Hong Kong Inland Revenue Department (IRD) has released updated lists of Qualifying Debt Instruments (QDIs) as at 30 September 2025.

The updated lists cover:

  • QDIs issued before 1 April 2018, comprising:
    1. Short- and medium-term QDIs eligible for a 50% Profits Tax concession under section 14A(1) of the Inland Revenue Ordinance; and
    2. Long-term QDIs eligible for Profits Tax exemption under section 26A(1), applicable from the 2003/04 year of assessment.
  • QDIs issued on or after 1 April 2018, which are intended to qualify for Profits Tax exemption under section 14A(1B), effective from the 2018/19 year of assessment.

The QDI lists primarily include debt instruments issued by financial institutions and government entities across the Asia-Pacific region, along with a limited number of other issuers.

Source – List of Qualifying Debt Instruments

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied