Background
1. The Taxpayer is a citizen and resident of Australia and was the sole director and
shareholder of a company, ABC Ltd (in liquidation) (ABC). The Taxpayer performed the
services which are the subject of this dispute in New Zealand.
2. ABC was registered for GST on the payments basis. ABC’s business was “Computer
Programming Service”. ABC did not have its own bank account, but an Australian
company with a similar name (ABC Pty Ltd (ABC Aus)) did have a New Zealand bank
account. The Taxpayer was the sole signatory on ABC Aus’ bank account.
Source: govt.nz
