Advocacy Report Reader


Advanced Manufacturing Industry Transformation Plan

Published: July 22, 2022

Submitting To: Ministry of Business, Innovation and Employment (MBIE)

Issue for Business: MBIE has consulted with the public on a plan of suggested work to accelerate the growth and transformation of the advanced manufacturing sector in New Zealand.

Action: BusinessNZ wrote in support of the goals outlined in the ITP and commented specifically on the chapters on; making the RSI system work for advanced manufacturing, attracting and developing a skilled workforce, and enhancing global connectivity and opportunities.

Outcome: Awaiting the final draft of the ITP.


Supporting NZ’s Economic Stability – Consultation on 5-year review of the Remit that guides monetary policy decisions

Published: July 13, 2022

Submitting To: Reserve Bank of New Zealand

Issue for Business: The Reserve Bank is legislated to achieve price stability and support maximum sustainable employment as the goals of monetary policy. The Reserve Banks specific operating guidelines from the Government for achieving this purpose are contained in the monetary policy Remit. The Consultation document looks at the merits of including other factors within the remit such as House Price Stability, Distributional Outcomes and Climate Change.

Action: BusinessNZ has made a submission expressing concern about the potential for the Reserve Bank to lose focus on its principal objective of Price Stability if a lot of new areas are covered within the Remit. It is also important that the Reserve Bank maintains credibility with the general public in respect to maintaining price stability.

Outcome: The Reserve Bank will be reviewing submissions on the Consultation Document over the next couple of months before outlining a draft proposal for further consultation later this year.

Environment & Infrastructure

Proposed Changes to the Wetland Regulations

Published: July 8, 2022

Submitting To: Ministry for the Environment (MfE)

Issue for Business: Government is revising the wetland regulations given the potential unintended consequences of the initial regulations

Action: BusinessNZ has made a submission generally supporting the proposed changes but suggesting further changes to ensure the regulations do not hinder economic development.

Outcome: Awaiting introduction of final regulations

Export & Trade

New Zealand’s Participation in the Indo-Pacific Economic Framework for Prosperity

Published: June 20, 2022

Submitting To: Ministry of Foreign Affairs and Trade (MFaT)

Issue for Business: MFAT have asked for submissions on New Zealand's participation in the US-initiative "Indo-Pacific Economic Framework for Prosperity". The Framework is designed to re-engage the US in the Indo-Pacific through four pillars: Fair & Resilient Trade; Supply Chain Resilience; Infrastructure, Clean Energy, & Decarbonisation; and Tax & Anti-Corruption.

Action: ExportNZ believes there are significant opportunities and positive outcomes for New Zealand should it be involved in the Framework and we, therefore, lend our initial support to New Zealand’s participation in IPEF. In particular, ExportNZ supports New Zealand’s participation in three of the four pillars: Fair & Resilient Trade; Supply Chain Resilience; and Infrastructure, Clean Energy, & Decarbonisation.

Outcome: Awaiting Decision from MFAT on NZ Participation.


Public Consultation on Working for Families Tax Credits

Published: June 6, 2022

Submitting To: Ministry of Social Development

Issue for Business: BusinessNZ has long held the view that Working for Families (WFF) represents a highly inefficient mechanism in which working New Zealanders receive additional financial support. Instead, an obvious means of addressing this issue is to leave the value of government assistance in people’s pockets in the first place. This means adjusting tax rates and thresholds rather than introducing new ways of distributing the tax take. Except for those genuinely unable to work, this would act as a primary incentive to work. It would also mean that increases in net income would need to be achieved through effort and productivity. At the very least, BusinessNZ believes the Government needs to take a step back and undertake a long overdue comprehensive root and branch review of WFF. We believe this would create a formal platform to discuss the significant inefficiencies that have plagued the policy since it began.

Action: In progress.


New Zealand Freight & Supply Chain Issues Paper

Published: June 3, 2022

Submitting To: Ministry of Transport (MoT)

Issue for Business: MoT have released an issues paper for consultation regarding the next 30 years of New Zealand's freight and supply chain system.

Action: Business New Zealand, Export New Zealand, and the BusinessNZ Energy Council welcome the opportunity to contribute at this early stage on the Ministry of Transport New Zealand Freight & Supply Chain issues paper.

Outcome: Awaiting Next Phase of the Policy Development Process.

Environment & Infrastructure

Transforming Recycling Consultation Document

Published: May 17, 2022

Submitting To: Ministry for the Environment (MfE)

Issue for Business: The Government wants to improve recycling rates in NZ given that they are generally low per capita compared to many other countries. MfE has issued a Consultation Document which covers 3 broad proposals. 1. Container Return Scheme (CRS) 2. improvements to household kerbside recycling, and 3. Separation of business food waste.

Action: BusinessNZ has put in a submission generally supporting the sentiment outlined in the Consultation Document towards improving the rate of recycling but outlining a broad range of issues which need to be addressed before any of the proposals are finalised and/or implemented.

Outcome: Awaiting Government Decisions


Dividend Integrity and Personal Services Income Attribution

Published: April 29, 2022

Submitting To: Inland Revenue Department (IRD)

Issue for Business: Unlike our standard submission process, BusinessNZ and the Corporate Taxpayers Group (which share a very similar membership base) prepared a joint letter on this discussion document that was sent to the Ministers of Finance, Revenue and Small Business on 28 April. The letter is included in our submission and outlines our main concerns with Inland Revenue’s proposals. Overall, we do not support the key proposals outlined, and believe they represent a significant overreach and will apply far wider than transactions which have been deliberately entered into in order to avoid the 39% tax rate.

Action: Submission sent 29 May.

Outcome: Awaiting submission review.


Driving Change: Reviewing the Road User Charges System

Published: April 20, 2022

Submitting To: Waka Kotahi NZ Transport Agency

Issue for Business: NZ Transport Agency wants to recover costs of damage to roads while also addressing other issues with little relation to distance travelled or vehicle weight within RUC.

Action: BusinessNZ is seriously concerned about the use of RUCs as a de facto mechanism for achieving other government objectives, such as promoting greater use of EVs to lower greenhouse gas emissions. The net impact is likely to be less money available for spending on roads as different transport modes are cross-subsidised by petrol-and diesel-powered vehicles. Second, many so-called externalities associated with on road transport - greenhouse gas emissions and accidents for example - are respectively already covered by the Emissions Trading Scheme (ETS) and by accident compensation (funded by the Motor Vehicle Account via petrol levies, Motor Vehicle Registration levies and vehicle insurance levies). One of BusinessNZ’s key points in our submission is that if after a thorough review of the RUC system, in government’s opinion there is a sound public policy reason for the continued cross-subsidisation of any new or existing road users e.g., EV owners, the nature of the subsidisation should be made transparent, and funding provided from general taxation. The funding will then show clearly in the government accounts, allowing the quality of the expenditure to be judged alongside all other areas of government expenditure.

Outcome: Awaiting Government decisions


Tax, Foreign Investment and Productivity draft long-term insights briefing

Published: April 14, 2022

Submitting To: Inland Revenue Department (IRD)

Issue for Business: BusinessNZ took the opportunity to submit in September 2021 on IRD’s previous Document that consulted on its proposal to focus its 2022 Long Term Insights Briefing (LTIB) on tax and its impact on investment and productivity. We agreed on this focus given investment and productivity are important factors affecting long-term living standards in New Zealand. Therefore, we are pleased to see the release of the current Document, and broadly support the LTIB process whereby key future issues are examined by Government Departments every three years. The Document examines a number of potential measures to initiate a process of discussion around how to improve New Zealand’s inbound investment. Therefore, BusinessNZ outlines its priorities for future work. Overall, we believe a reduction in the company tax rate is the best initial step forward, although as mentioned in the Document there is no one silver bullet, so any option(s) chosen will also require broader remedial changes to the tax system.

Action: Submission sent on 14 April 2022

Outcome: Awaiting review of submissions


Tax Administration in a Digital World: An officials’ issues paper to support future tax administration

Published: March 31, 2022

Submitting To: Inland Revenue Department (IRD)

Issue for Business: IRD are currently looking at possible policy changes required to support a more digital tax system. This covers frameworks for considering policy changes, and what the shift to digital could mean for a more digital tax system, taxpayers, Inland Revenue, and digital inclusion. It also covers specific areas for feedback, including: • The regulatory framework applying to external parties, including intermediaries and other entities which interact with the tax and payments system; • The rules, frameworks and scope of data sharing; and • How tax legislation could support a more digital future. To assist IRD in terms of their early thinking around a more digital tax administration system, members may recall BusinessNZ (with the assistance of the BusinessNZ Tax Group) released a white paper in November last year entitled The Future of Tax Administration in New Zealand. The Paper looked at how New Zealand’s tax administration could be improved with better technology and more partnerships with the private sector. The BusinessNZ Tax Group white paper can be viewed here: We note there is much cross-over between the BusinessNZ Paper and the IRD one. Overall, we support the work IRD are doing in this space, and believe the IRD Paper is a good first step to ensuring a collaborative effort between Government and the private sector takes place.

Action: Submission sent on 31 March.

Outcome: Awaiting submission review.


Price discovery under 100% renewable electricity supply

Published: March 16, 2022

Submitting To: Electricity Authority

Issue for Business: The paper describes how our electricity supply system is likely to change physically with 100% renewable electricity supply and the likely impact on prices. The paper identifies seven key issues to be addressed: Real-time co-ordination, Ancillary services, Accurate price signals, Demand-side flexibility, contracts, orderly transition, and competition. In general, we agree with MDAG’s views on how electricity supply is likely to change and with the issues identified. This submission provides our view of the future according to our modelling, some general comments on the issues identifies, as well as some other wider risks to consider.