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Submissions

From time to time we make submissions on Government policy, with a focus on issues that are relevant to our investment mandates or directly impact the Guardians.

Here you will find the past submissions we have made to legislative and regulatory bodies.

2023/24

Submission on Proposed 2024 Amendments to Climate and Assurance Standards

Submission to the Financial Markets Authority on Prospective Financial Information

Submission on the Companies (Address Information) Amendment Bill
Inquiry into the Amendments to Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Bill 2023 Submission by Foreign Funds
Joint submission on Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Bill to Treasury
Joint submission on Treasury Laws Amendment (Making Multinationals Pay Their Fair Share - Integrity and Transparency) Bill to Senate Standing Committees on Economics
Submission on the European Commission: Proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes
2022/23
Joint submission to the Australian Treasury on interest limitation rules
Submission to the Economic Development, Science and Innovation Committee on Business Payment Practices Bill
Submission to the Finance and Expenditure Committee on Taxation (Annual Rates for 2022-23, Platform Economy, and Remedial Matters) Bill (No 2)
Submission to HM Treasury on Consultation Document: Sovereign immunity from direct taxation
Submission on Changes to Anti-Money Laundering and Countering Financing of Terrorism Act 2009
Submission on the draft Ngā Tikanga | The Code of Conduct
Startup Advisors Council Submission - March 2023
2021/22
Submission to the Ministry of Business, Innovation and Employment's discussion document - A Legislative Response to Modern Slavery and Worker Exploitation: Towards, freedom, fairness and dignity in operations and supply chains
Submission to the External Reporting Board on Aotearoa New Zealand Climate Standard 1 Climate-related Disclosures: Strategy, and Metrics and Targets Consultation Document
Submission to the Ministry for the Environment on the Emissions Reduction Plan: 'Te hau mārohi ki anamata - Transitioning to a low-emissions and climate-resilient future' 
Submission to the External Reporting Board on Aotearoa New Zealand Climate Standard 1 Climate-related Disclosures: Governance and Risk Management Consultation Document 

Submission to the Climate Change Commission on Climate Action for Aotearoa 

Submission to the New Zealand Infrastructure Commission on the consultation document 'He Tūāpapa ki te Ora, Infrastructure for a Better Future'

Joint Comments to the OECD Centre for Tax Policy and Administration on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy
2020/21

Submission to the International Financial Reporting Standards (IFRS) on sustainability reporting

Joint Comments to the OECD Centre for Tax Policy and Administration on Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint - public consultation document

Submission on the Urban Development Bill
2019/20

Submission to the Commission for Financial Capability's 2019 Review of Retirement Income Policies

Submission to the Ministry for the Environment and the Ministry of Business, Innovation and Employment on the Climate-Related Financial Disclosures Discussion Document

Joint Submission to the OECD on its Public Consultation Document "Global Anti-Base Erosion Proposal ('GloBE') - Pillar Two

Comment letter
Joint Submission to the US Department of Treasury on proposed regulations under section 897(1) (FIRPTA)
Submission to the Ministry for the Environment on discussion document on action on agricultural emissions
Submission to the Finance and Expenditure Committee on the Agreement between the Government of New Zealand and the Government of the People's Republic of China for the Elimination of Double Taxation
Submission to the Treasury on reform of the Overseas Investment Act 2005
Submission to the Finance and Expenditure Committee on the New Zealand Infrastructure Commission / Te Waihanga Bill
Submission to the Finance and Expenditure Committee on Taxation (Annual Rates for 2019 - 2020, GST Offshore Supplier Registration, and Remedial Matters) Bill
Joint Submission to the OECD on their public consultation document: Addressing the tax Challenges of the Digitalisation of the Economy
Submission to the Productivity Commission on Local Government funding and financing
2018/19

Presentation to the Tax Working Group

Follow-on Letter (via email) 
Submission to the Treasury on consultation document re A New Independent Infrastructure Body
Submission to the State Services Commission on State Services Reform
Submission to the Ministry of Business, Innovation & Employment on Directors' residential addresses
Submission to the Australian Treasury re Stapled Structures - Integrity Package (second stage)
Submission to the Australian Treasury re Stapled Structures - Reform Package
Submission to the Tax Working Group on Nationally Significant Infrastructure
Submission to the NZX on the second stage of the Listing Rule review
Joint Submission to the NZX on the second stage of the Listing Rule review
Response to the Productivity Commission's Report on the Low-Carbon Economy
Submission to the Tax Working Group on the Future of Tax: Submissions Background Paper
Submission to the Governance and Administration Select Committee on the State Sector and Crown Entities Reform Bill, Questions, Presentation
Joint Submission to the US Treasury - Comments Addressing Section 897(1) Qualified Foreign Pension Fund Requirements
Joint Submission to the US Treasury - Comments Addressing Section 892 Regulations in respect to the Income of Foreign Governments
Submission to Treasury on Overseas Investment in Forestry
2017/18
Submission to discussion paper on the review of the NZX Main Board Listing Rules
Submission to the FMA on the Corporate Governance handbook
Joint Submission to the US Treasury: Interest Deductibility Tax Provisions Impacting Foreign Investment in the United States
Submission to the Financial Markets Authority on Substantial Product Holder Disclosures
Submission to the Australian Treasury in relation to their consultation on Stapled Structures
Joint Submission to the Organisation for Economic Co-Operation and Development on its Public Discussions Draft "BEPS Action 6 - Discussion Draft on non-CIV examples"
Submission to the NZ Productivity Commission on transitioning to a Low Emissions Economy
Submission to the class waiver for SME Listings - NZX Main Board Listing Rules 5.2.3; 7.3.1; 7.4; 9.1.1 and 9.2.1
Submission to RBNZ on Consultation Document: A New Zealand Response to Foreign Margin Requirements for OTC Derivatives
Joint Submission on the Reserve Bank’s Issues Paper: Review of the Capital Adequacy Framework for Locally Incorporated banks
2016/17
Submission to the revision of the NZX Corporate Governance Code
Submission to the US Department of the Treasury and the US Internal Revenue Service regarding the Qualified Foreign Pension Fund exemption
Joint Submission to the Organisation for Economic Co-operation and Development on BEPS Action 6 - Treaty entitlement of non-CIV funds
Joint Submission to the Organisation for Economic Co-operation and Development on its Public Discussion Draft on the Treaty Residence of Pension Funds - Definition of Recognised Pension Fund
Submission to NZX on corporate governance reporting requirements within the NZX Main Board Listing Rules
Submission to the New Zealand Emissions Trading Scheme Review 2015/16: Priority Issues

Submission to the 2016 Retirement Policy Review: The NZ Super Fund and the partial pre-funding of universal superannuation 

Prepared at the request of the Commission for Financial Capability.
2015/16
Submission to the Australian Stock Exchange consultation on Reverse Takeovers
Joint Submission to the Organisation for Economic Co-operation and Development on its Revised Discussion Draft “BEPS Action 6: Prevent Treaty Abuse”

Submission by KPMG on behalf of NZSF and QIC to the OECD on BEPS Action 6 Public Discussion Draft - Impact on Institutional Investors
2014/15
Submission to the Financial Markets Authority on Corporate Governance in New Zealand - Principles and Guidelines
Submission to the Financial Markets Authority on SIPOs and Limit Breaks
Submission to the Finance and Expenditure Select Committee on the New Zealand Superannuation and Retirement Income Amendment Bill
2013/14

Submission to the External Reporting Board regarding the ED49 Consolidated Financial Statements

Feedback on the Commission for Financial Literacy and Retirement Income's 2013 Discussion Paper on Retirement Income Policy.

The Commission's final 'Focusing on our Future' Report to the Government

Published in December 2014, see pages 54-56 for information on the Fund.

Discussion Paper on the Role and Performance of the New Zealand Superannuation Fund

Prepared at the request of the Commission for Financial Literacy and Retirement Income.

The Commission's Discussion Paper

The discussion paper includes information about the role and performance of the Fund on pages 55-56.
2012/13

Submission on the Consultation Draft of the State Sector Reform Bill

Submission to the External Reporting Board on the proposed Public Benefit Entities accounting standards and the guidance for Mixed Groups
2011/12

Submission to the International Accounting Standards Board on the Investment Entities Exposure Draft
2010/11

Submission to the Official Information Legislation Review ("The Public's Right to Know")

Submission to the Savings Working Group

The Terms of Reference for the Savings Working Group

Submission to the Commerce Select Committee on Financial Advisers

Submission to the Securities Commission on the NZSX Listing Rule Review
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