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From Adjustment to Apportionment in the Goods and Services Tax Act: A Comparative Analysis of the Change-In-Use Rules in Australia, Canada, and New Zealand

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posted on 15.11.2021, 06:38 by Greening, Mark J.

All countries that have adopted Goods and Services Tax (GST) or Value Added Tax (VAT) employ a ‘change-in-use’ mechanism to distinguish consumption from the stages of production and distribution. New Zealand’s former change-in-use rules were unique. Unlike the ‘use’ based apportionment approaches employed in Australia, Canada and the United Kingdom, New Zealand employed an adjustment approach that utilised a ‘principal purpose’ test and deemed supply mechanism. While Canada has also employed an adjustment approach for capital property, the New Zealand rules have operated differently to those in Canada. In response to criticism for being overly complex and confusing, the New Zealand change-in-use rules will adopt a new ‘use’ based apportionment approach, together with a new mechanism to constrain the number of adjustments, from 1 April 2011 for a number of taxpayers. Applying criteria identified by the Tax Working Group the performance of New Zealand’s change-in-use rules are examined, in comparison to those applied in Australia and Canada. In addition, the comparative readability of the change-in-use provisions in all three jurisdictions is examined. The paper concludes that New Zealand should adopt an apportionment approach and that the Goods and Services Tax Act should be rewritten for improved readability.


Copyright Date


Date of Award



Te Herenga Waka—Victoria University of Wellington

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Author Retains Copyright

Degree Discipline


Degree Grantor

Te Herenga Waka—Victoria University of Wellington

Degree Level


Degree Name

Master of Law

Victoria University of Wellington Item Type

Awarded Research Masters Thesis



Victoria University of Wellington School

School of Law


White, David