Abstract:
The New Zealand Commissioner of Inland Revenue issues
several kinds of statements that are in effect legal opinions.
This article relates to certain public statements formerly
known as “policy statements” and now called “interpretation
guidelines”. The change of name occurred in 1995, when the
department was reorganised and two new divisions were
formed: Policy Advice and Adjudications and Rulings.
“Policy statements” became the responsibility of
Adjudications and Rulings. The new name of “interpretation
guidelines” was chosen to avoid misleading people into
thinking that such statements emanate from the Policy Advice
Division.
As a preliminary matter, it is helpful to distinguish
interpretation guidelines from other forms of opinions or
statements that the Commissioner issues. There are two
primary groups of such statements: binding rulings and
standard practice statements.
