Income Tax Act 2007

Memorandum accounts - Imputation credit accounts (ICA)

OB 42: ICA on-market cancellation

You could also call this:

"What happens when a company buys back its own shares and has a special debt to pay"

Illustration for Income Tax Act 2007

When a company buys back its own shares, it might have an imputation debit. This debit is calculated using a formula. You need to know what the ASC per share excess and the tax rate are to use the formula. The ASC per share excess is the amount left over after the company pays out the available subscribed capital per share. The tax rate is the basic rate of income tax, which you can find in schedule 1. If the formula gives a negative result, the debit is treated as zero. The debit date is the day the company buys back the shares.

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"Company loses tax credit when shareholders change significantly"


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OB 43: ICA breach of imputation ratio, or

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Part OMemorandum accounts
Imputation credit accounts (ICA)

OB 42ICA on-market cancellation

  1. When an ICA company acquires its shares in an on-market cancellation, it has an imputation debit for an amount calculated using the formula—

    ASC per share excess × tax rate ÷ (1 − tax rate).

    Where:

    • In the formula,—

    • ASC per share excess is the amount distributed on the on-market cancellation that is more than the amount of the available subscribed capital per share calculated under the ordering rule:
      1. tax rate is the basic rate of income tax set out in schedule 1, part A, clause 2 (Basic tax rates: income tax, ESCT, RSCT, RWT, and attributed fringe benefits) for the tax year in which the acquisition occurs.
        1. The imputation debit in subsection (1) is referred to in table O2: imputation debits, row 15 (on-market cancellation).

        2. If the formula produces a negative result, the debit is treated as zero.

        3. The debit date is the day the shares are acquired by the company in the on-market cancellation.

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        Notes
        • Section OB 42(1) formula: amended, on , by section 498(1) of the Taxation (Business Taxation and Remedial Matters) Act 2007 (2007 No 109).
        • Section OB 42(2)(b): substituted, on , by section 498(2) of the Taxation (Business Taxation and Remedial Matters) Act 2007 (2007 No 109).