1 Nov 2018
NRS MEDIA HOLDINGS LTD v COMMISSIONER OF INLAND REVENUE [2018] NZCA 472
- Citation
- [2018] NZCA 472
- Court
- Court of Appeal
The Court held that s DB 55 must be applied using ordinary nexus principles rather than a special, more restrictive 'direct causal' test; NRS's recurrent corporate/head office expenses had a sufficient factual nexus to deriving the exempt foreign dividends and, assessed from a practical and business point of view, were revenue (not capital) in nature and therefore deductible under s DB 55 despite the section's exemption override not removing the capital limitation.