Actually Suren, you're not quite right in this particular
case. The Brierley situation is because the company is now becoming a non
resident in what is known, in terms of NZ's taxation legislation, a non
'grey list' country, ie, Singapore. If an investor owns more than $20,000
worth of shares in non grey list countries, then they invoke the provisions
of NZ's 'Foreign Investment Fund' regime. Under the FIF regime, there are
from memory actually four ways of calculating a single NZ investors taxable
income, which effectively end up taxing that investor on any realised or
unrealised capital gains earned from those non resident companies,
regardless of whether they are classed as a share trader here or not.
See IRG research reports
