Section EX 27 — Income Tax Act 2007: Anti-avoidance rule: stapled stock

EX 27 Anti-avoidance rule: stapled stock When this section applies (1) This section applies when— (a) a New Zealand resident holds rights (the stapled rights ) that give rise to an income interest or control interest in a foreign company; and (b) the rights may, or may ordinarily, be disposed of only together with rights in another company; and (c) the other company is a New Zealand resident or a CFC. Stapled rights held by company (2) When each of subparts CQ (Attributed income from foreign equity) and DN (Attributed losses from foreign equity) and this subpart is applied, the stapled rights are held by the other company and not by the person. Defined in this Act: CFC , company , control interest , foreign company , income interest , New Zealand resident , Compare: 2004 No 35 s EX 28