New Zealand · Consultation
New Zealand consults on consolidated land GST zero-rating guidance
On 16 October 2026, New Zealand’s Inland Revenue opened consultation on consolidated guidance for compulsory GST zero-rating of land. Comments on PUB00525 close on 27 November 2026.
- Official document:
- PUB00525; Goods and Services Tax Act 1985 sections 11(1)(mb), 11(8D) and 78F
- Development date:
- 2026-10-16
A consultation, not a new zero rate
The draft would replace IS 17/08 and QB 21/08. It concerns interpretation of the Goods and Services Tax Act 1985, rather than introducing a new tax concession. Inland Revenue expressly warns that draft items cannot be relied on as authoritative statements.[2]
The existing 2017 statement explains the core section 11(1)(mb) conditions: the vendor’s supply must be in the course or furtherance of a taxable activity; both parties must be registered, or liable to be registered, at settlement; the purchaser must intend taxable use; and no land may be intended as the purchaser’s or a relative’s principal residence. These are established concepts, not changes announced this October.[3]
Commercial leases require their own analysis
QB 21/08 already addressed assignments, surrenders and lease procurement in business sales under section 11(8D). Its 2021 analysis also addressed large irregular payments and subsequent rent. The subject was consequently not absent from the earlier guidance.[4]
The new draft distinguishes treatment from 1 April 2023: for commercial leases of at least one year, where combined irregular lump-sum payments exceed 25% of total consideration and the core conditions are met, only those payments are zero-rated; regular rent remains standard-rated. It dates the underlying legislative change to 2023, not 2026.[2]
Settlement information remains central
The draft’s section 78F discussion covers purchaser registration and intended-use information, including nominees, and corrections where information is wrong or incomplete. For multinational groups acquiring business premises or transferring businesses, our practical reading is to connect the GST review with the actual recipient and settlement documentation. The consultation does not itself change contractual or statutory obligations.[2]
Official sources
- [1] PUB00525 consultation: Goods and Services Tax – Compulsory zero-rating of land rules
Inland Revenue · Document date: 2026-10-16
Competent consultation page lines54–90: open16October2026, closes27November2026, current consultation status and original45-page draft link. Event date comes from this page, not PDF metadata or placeholder issue date.
- [2] PUB00525 exposure draft: Goods and Services Tax – Compulsory zero-rating of land rules
Inland Revenue · Document date: 2026-10-16
45-page original, SHA2560fd3ad747f8d7ea98ea51e39c150d8dc70a336817bce6b381f686eef654bead7. Contents/summary pp1–5; selected analysis paras49–64 pp15–18,65–83 pp21–25,96–127 pp29–38; correction table p41 and draft-reliance warning p42. Actual rendered pages1/17/36 inspected. Footnotes28–32 date the 2023 lease changes; paras75–83 reference78F. Current whole Act not independently certified: discovered legislation page returned403 and was not retried. This article reports the consultation’s interpretation, not a legal amendment.
- [3] IS 17/08: GST – Compulsory zero-rating of land rules (general application)
Inland Revenue · Document date: 2017-09-15
Competent landing confirms15September2017 issue. Selected original31-page statement printedpp8–9 paras36–40: core11(1)(mb) conditions and registration including liability. Historical comparator, not a claim that its full2017 legislative appendix is current in2026.
- [4] QB 21/08: GST – How do compulsory zero-rating of land rules apply to commercial leases?
Inland Revenue · Document date: 2021-06-29
Original12-pagePDF cover and printedpp1–5, answer and paras1–22:11(1)(mb)/11(8D), lease assignments/surrenders/procurement and historical treatment of large irregular payments/subsequent rent. Used only as dated2021 comparator.