✨ Income Tax Determination Example
23 DECEMBER
NEW ZEALAND GAZETTE
Under the Forward Commodity Purchase agreement, A has paid $2,000 to B on 1 January 1993, as full payment for the abovementioned deliveries. A funded this $2,000 through a Base Currency Loan from C, which is repayable in installments due on the abovementioned dates.
Under the Commodity Price Swap agreement, A agrees to pay a sum equal to the market value of the commodity on the abovementioned delivery dates (the Floating Price Swap). Another party agrees to pay A $1.00 per unit on the same dates and for the same quantities (the Fixed Price Swap).
Although payment obligations under the Commodity Price Swap agreement are fixed and incurred on the above dates, payment may not be made until 6 months later.
When A receives the commodity on the delivery date, it then on-sells. Again, payment for this on-sale may not be made until 6 months later.
For the relevant period, the following assumptions are made:
(a) the commodity price was increased at a uniform rate, being:
| Date | Price |
|---|---|
| 1 January 1993 | $1.00 |
| 1 July 1993 | $1.20 |
| 1 January 1994 | $1.40 |
| 1 July 1994 | $1.60 |
| 1 January 1995 | $1.80 |
(b) the Base Currency $ rate to NZD has moved at a constant rate, being:
| Date | Rate |
|---|---|
| 1 January 1993 | 1.00 |
| 1 July 1993 | 0.95 |
| 1 January 1994 | 0.90 |
| 1 July 1994 | 0.85 |
| 1 January 1995 | 0.80 |
A shall have the following income/expenditure.
In respect of the Forward Commodity Purchase Agreement
At first balance date – 31 December 1993
a = $2,500
b = 750 × $1.40 = $1,050
c = 1000 × $1 + 750 × $1.20
= $1,000 + $900
= $1,900
d = $2,500
e = $750
f = 1,000 × $2,000 + 750 × $2,000
= $2,000 + $1,500
= $3,500
Income/expenditure is:
2,500 + 1,050 + 1,000 + 900 − 2,500
1.0 0.9 1.0 0.95 1.0
= 750 + 800 − 600
0.9 1.0 0.95
Base Currency = $800
NZD = $849
At the second balance date – 31 December 1994
a = $750
b = 0
c = 500 × $1.40 + 250 × $1.60
= $700 + $400
= $1,100
d = 750 × $1.40
= $1,050
e = 0
f = 500 × $2,000 + 250 × $2,000
= $1,000 + $500
= $1,500
Income/expenditure is:
750 + 0 + 700 + 400 − 1,050 − 0
0.9 0.9 0.85 0.85
= 400 − 200
0.9 0.85
Base Currency = ($200)
NZD = ($210)
In respect of the Base Currency Loan Agreement
At the first balance date – 31 December 1993
Base Currency = $200
NZD = $235
c = 1,500 × $2,000 + 750 × $2,000
2,500 2,500
= $800 + $600
f = $1,000 + $750
Income/expenditure is:
800 − 1,000 + 600 − 750
1.0 1.0 0.95 0.95
Base Currency = ($350)
NZD = ($358)
At the second balance date – 31 December 1994
c = 500 × $2,000 + 250 × $2,000
2,500 2,500
= $400 + $200
f = $500 + $250
Income/expenditure is:
400 − 500 + 200 − 250
0.9 0.9 0.85 0.85
Base Currency = ($150)
NZD = ($170)
In respect of the Floating Price Swap
Under subclause 6 (9) there is no income or expenditure in either income year.
In respect of the Swap
At the first balance date – 31 December 1993
a = $2,500
b = $750
c = $1,000 + $750
= $1,750
d = $2,500
e = 750 × $1.40
= $1,050
f = 1,000 × $1 + 750 × $1.20
= $1,000 + $900
= $1,900
Income/expenditure is:
2,500 + 750 + 1,000 + 750 − 2,500
1.0 0.9 1.0 0.95 1.0
= 1,050 − 900
1.0 0.95
Base Currency = ($450)
NZD = ($491)
At the second balance date – 31 December 1994
a = 750 × $1.40
= $1,050
b = 0
c = $500 + $250
= $750
d = 0
e = 0
f = 500 × $1.40 + 250 × $1.60
= $700 + $400
= $1,100
Income/expenditure is:
1,050 + 0 + 500 + 250 − 750 − 0 − 700 − 400
0.9 0.9 0.85 0.85 0.9 0.9 0.85
Base Currency (BCD) = ($50)
NZD = ($65)
Adding all 3:
At the first balance date – 31 December 1993
NZD = $849 − $358 − $491 = $0
BCD = $800 − $350 − $450 = $0
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VUW Te Waharoa —
NZ Gazette 1992, No 208
NZLII —
NZ Gazette 1992, No 208
✨ LLM interpretation of page content
💰
Income Tax Determination on Funding and Hedging Arrangements
(continued from previous page)
💰 Finance & Revenue8 December 1992
Income Tax, Financial Regulations, Forward Commodity Purchase, Commodity Price Swap