Leary Ingrid; Salesa JennyINGRID LEARY (Labour—Taieri): Thank you Madam Speaker. I'm a little bit baffled by the last speaker's reference to dual residency and saying that this is something that needs to be looked at because actually this dual-residency question is one of the significant changes that this bill introduces which bring significant benefit to business. It hasn't actually been discussed much in the House. So I will turn my attention to it in my contribution this morning.It comes as a result of uncertainty on corporate residency tax. So that's when the majority of directors could be say from Australia a New Zealand company that has all its operations in New Zealand could actually be considered a dual tax resident and then that has some flow-on effects currently which would disadvantage it. That comes about from recent changes in the Australian Taxation Office which has led to the ambiguity. So to follow Michael Woodhouse's analogy on rugby it's a little bit like the Aussies claiming our New Zealand All Blacks simply say the coach was an Australian and all the All Blacks and the games happened in New Zealand—that is currently what could happen with this ambiguity in the tax changes.So under the New Zealand current rules there are several benefits that can be claimed in these tax regimes. One of them is around forming consolidated goods. Until now that has been for New Zealand - only companies. What that basically means is that wholly owned groups of companies can be considered for tax purposes as one group so their assets transfers dividends interest management fees and so on can be considered together.Secondly there's the sharing of tax loses. So that's sharing losses between loss- and profit-making companies where there's at least 66 percent shared ownership.And thirdly the utilisation of imputation credits. So that's about a fair and transparent spread of tax burden and benefit between shareholders and a company. So imputation credits basically mean tax credits can go to shareholders and if the imputation credit account is in debit a company could be required to pay more tax. Now these benefits don't normally apply to non - New Zealand resident companies. So what this bill is seeking to do is to ensure that New Zealand resident companies can continue to have those benefits even where they're considered dual resident by Australia. So the question then becomes: when is a New Zealand company a New Zealand resident? Basically if it's incorporated in New Zealand if its head office is in New Zealand or if the centre of management or the directors control the company in New Zealand. None of that was ambiguous until 2017 when there was a case called Bywater where the Australian tax company revised its views on residency and made it possible for New Zealand companies to be considered dual residents if the majority of their directors were based in Australia. So that would be even if there was no trading or no investment overseas. Now that hasn't been determined yet. At the moment it's still the status quo but that case law has opened up the possibility for New Zealand companies to be disadvantaged should that happen.The other point I'd just like to pick up is around compliance and the Opposition saying that there are heavy compliance costs. Actually what this bill seeks to do around GST is to reduce compliance costs particularly again for overseas situations around PAYE around employing overseas contractors. It has been a headache for business particularly if they were expecting an exemption and the exemption isn't granted. What the bill seeks to do is basically simplify the process—so for example with PAYE allow it to be paid annually by New Zealand companies rather than monthly.So in summary these international compliance benefits are nimble thoughtful and good for business. They protect New Zealand business from a dual-tax burden and that's a great thing. And it's just something for us to bear in mind as we consider what some of the significant benefits are of this bill that haven't actually really been raised until today.ASSISTANT SPEAKER (Hon Jenny Salesa): The next call is a split call. I call on the Hon Michael Woodhouse for five minutes.