Abstract:
New Zealand’s foreign trust regime (FTR) has courted much controversy over the years. This article considers the extent to which the FTR can be considered neighbourly in a global context. Such an investigation provides an opportunity to consider not only how the FTR operates, but also the criticisms to which it has been subjected. More generally, the principle of neighbourliness is considered as a norm for guiding nation states in the design and reform of those domestic tax rules that have an international dimension. Thus, this article considers the place of domestic tax systems in a rapidly evolving international tax environment. Given the particular focus on the FTR, what emerges is the realisation that, in its current form, the FTR is inconsistent with the principle of neighbourliness.