Five years after paying $413.7 million to settle a huge tax avoidance claim, ANZ bank is under fire for a $1 billion deal that appears to "double dip" on trans-Tasman tax benefits.
The criticism follows the Australian bank's issue this month of A$970 million ($995 million) of hybrid securities to finance its New Zealand operations. Veteran businessman and tax campaigner Tony Gibbs described the issue as "very smelly".
While the income on the notes counted as interest in New Zealand, generating a tax deduction for the New Zealand bank, it was treated as dividend across the Tasman, allowing Australian investors to access tax credits.
"It sounds to me like double dipping," he said.
IRD commissioner Robert Russell said the 2009 deal confirmed its long-held view that the transactions were tax avoidance.
So, the obvious question: will the IRD prosecute? And given that they are clearly repeat offenders, will we see ANZ's executives perp-walked in handcuffs as they deserve?