Notice Type
Departmental
Notice Title

Notice of Determination Regarding a Type of Interest in a Foreign Investment Fund for Which a Person May Not Use the Fair Dividend

Rate Method
1. This is a notice made under section 91AAO(5) of the Tax Administration Act 1994 of a determination made by the Commissioner of Inland Revenue under section 91AAO(1)(b) of that Act.
2. Determination FDR 2014/01 was made on 3 February 2014 that any investment a New Zealand resident investor makes in NZDH-A shares issued by Russell Investment Company plc (RIC) and the share class, which has a value in New Zealand dollars, is linked to an interest in a pool of debt securities held by Russell Global Bond Fund (a sub-fund of RIC) and effectively hedged against foreign currency movements by RIC, is a type of attributing interest for which a person may not use the Fair Dividend Rate method to calculate Foreign Investment Fund income from the interest for the 2015 and subsequent income years.
3. The determination will appear in Inland Revenue's Tax Information Bulletin, Vol. 26, No. 2, of March 2014 and will also be available on the Inland Revenue website
www.ird.govt.nz
JOHN TREZISE, Investigations Manager, Investigations and Advice, Inland Revenue.