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IRD Releases Its View On Proposed AMP Demerger


Inland Revenue today released its preliminary view on how it will view the tax issues arising from the proposed demerger of the UK businesses of AMP.

Naomi Ferguson, of Inland Revenue, said today that the demerger, if it proceeds as AMP has proposed, is likely to be tax neutral for the 90,000 New Zealand-resident shareholders affected who hold their shares as capital investments.

Ms Ferguson, General Manager (Service Delivery), said Inland Revenue had issued its preliminary view, based on detailed analysis of the AMP proposal, in order to provide certainty for AMP's New Zealand shareholders.

Inland Revenue's preliminary view is written up in an item called a QWBA - Questions We've Been Asked. The QWBA will be published in full in the next issue of the Tax Information Bulletin. This will be on the Inland Revenue website,, from 24 November.

The QWBA clarifies the New Zealand dividend consequences for New Zealand resident shareholders of AMP, by stating that it is not expected that any of the benefits emerging from the demerger will constitute dividends under New Zealand's tax rules.

Once the proposed demerger is completed, Inland Revenue will review its preliminary view and publish it in the Tax Information Bulletin.

Ms Ferguson emphasised however that the QWBA relates specifically to the AMP demerger. Other demergers or company spin-outs may have a different tax outcome. There is further information on "Company Restructuring: Demergers and Spin-outs" in the Tax Information Bulletin Volume 15, No 6 (June 2003), available on, in relation to three other Australian company demergers.


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