Financial Arrangements and Tax Positions




27 FEBRUARY NEW ZEALAND GAZETTE 411

Value of each FundCo Agreement after payment of FundCo Variable Payments

31 March 06 13,327
31 March 07 15,773

7.5 The value of TradeCo’s futures portfolio as at the end of each income year, after payment of the TradeCo Variable Payments is as follows:

Value of futures portfolio prior to TradeCo Variable Payments Value of futures portfolio after TradeCo Variable Payments
31 March 98 5,400 5,050
31 March 99 6,818 6,376
31 March 00 7,970 7,571
31 March 01 9,085 8,707
31 March 02 11,319 10,666
31 March 03 9,599 9,599
31 March 04 10,559 10,559
31 March 05 13,727 12,962
31 March 06 16,850 15,878
31 March 07 21,435 20,046

7.6 By way of example, calculations of the income derived/expenditure incurred by TradeCo, FundCo and Investor A and B for the year ending 31 March 2005 are set out below. The position for each such party over all years in question is then set out in table form.

Position of TradeCo for the year ending 31 March 2005

7.7 Income derived with respect to TradeCo’s portfolio of futures contracts is $3,168 (being the difference between the futures contracts, prior to the making of progress payments, on hand at 31 March 2005 and those on hand as at 31 March 2004, after having made progress payments).

7.8 Income derived/expenditure incurred with respect to the TradeCo Agreement:

a = $12,962
b = $765
c = $10,559

$12,962 + $765 – $10,559 = $3,168 expenditure incurred

Position of FundCo for the year ending 31 March 2005

7.9 Income derived/expenditure incurred with respect to the TradeCo Agreement:

a = $12,962
b = $765
c = $10,559

$12,962 + $765 – $10,559 = $3,168 income derived

7.10 Income derived under the Deposit:

$636 (refer profile at paragraph 7.2)

7.11 Income derived/expenditure incurred with respect to each FundCo Agreement:

a = $11,529
b = $383
c = $10,010

$11,529 + $383 – $10,010 = $1,902

Position of Investor A for the year ending 31 March 2005

7.12 Income derived/expenditure incurred with respect to the FundCo Agreement

a = $11,529
b = $383
c = $10,010

$11,529 + $383 – $10,010 = $1,902 income derived

Position of Investor B for the year ending 31 March 2005

7.13 As Investor B is a cash basis holder the income derived with respect to the FundCo Agreement is $383, being the only receipt for that year.

Position of TradeCo for all years

7.14 The tax position for TradeCo over the years in question is:

Income from futures contracts Expenditure in respect of TradeCo Agreement
31 March 98 1,400 (1,400)
31 March 99 1,768 (1,768)
31 March 00 1,594 (1,594)
31 March 01 1,514 (1,514)
31 March 02 2,612 (2,612)
31 March 03 (1,067) 1,067
31 March 04 960 (960)
31 March 05 3,168 (3,168)
31 March 06 3,888 (3,888)
31 March 07 5,557 (5,557)

Position of FundCo for all years

7.15 The tax position for FundCo over the years in question is as follows:

Income from TradeCo Agreement Income from Deposit Expenditure in respect of FundCo Agreements
31 March 98 1,400 403 (1,803)
31 March 99 1,768 431 (2,199)
31 March 00 1,594 459 (2,053)
31 March 01 1,514 490 (2,004)
31 March 02 2,612 524 (3,136)
31 March 03 (1,067) 558 509
31 March 04 960 596 (1,556)
31 March 05 3,168 636 (3,804)
31 March 06 3,888 679 (4,567)
31 March 07 5,557 724 (6,281)

Position of Investors A & B for all years

7.16 The tax position for Investor A and Investor B:

INVESTOR A Income with respect to FundCo Agreement INVESTOR B Income with respect to FundCo Agreement
31 March 98 901 175
31 March 99 1,099 215
31 March 00 1,026 201
31 March 01 1,002 195
31 March 02 1,568 306
31 March 03 (254) (50)
31 March 04 778 151
31 March 05 1,902 383
31 March 06 2,284 459
31 March 07 3,140 629


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💰 Issue of Capital Guaranteed Growth Notes and Related Financial Arrangements (continued from previous page)

💰 Finance & Revenue
Capital Guaranteed Growth Notes, Financial Arrangements, BNZ, FundCo, TradeCo