2017 NZSSAA 056 (9 October 2017) [pdf, 122 KB]
...based on his shareholder salary. [8] In all respects, the appellant was a compliant taxpayer and paid tax on all his income under the structure. In the year ending 31 March 2007, the appellant received a relatively similar amount of income from an offshore entity, where tax was paid at source. This was, accordingly, credited against his New Zealand tax liability. The balance of his income came from his shareholder salary and it was taxed fully in New Zealand. After that year, it...