Although COVID-19 travel restrictions have put a hold on most trophy hunting trips by overseas tourists, they have in the past been a significant earner for New Zealand guiding companies and are likely to be again once the lockdowns ease.
If you’re in the business of providing hunting experiences and trophies to overseas tourists it’s worth being aware of the recent Inland Revenue guidance on how to correctly account for the GST on these items.
Why is it so complicated?
The reason it is a complex tax area is that GST is a tax on consumption of goods and services, but only on consumption that occurs within New Zealand.
The question therefore is; if an overseas tourist purchases a hunting experience from a New Zealand hunting guide and that hunt results in a trophy which the tourist takes overseas, which portion of this experience is consumed in New Zealand (subject to 15% GST) and which portion is consumed overseas (subject to 0% GST)?
Inland Revenue (IR) has in the past been concerned that when hunting experiences and resulting trophies are packaged up and sold to overseas tourists, the zero-rated percentage can be artificially inflated in an effort to reduce tax payable.
In July 2020 IR issued a ‘Commissioner’s Statement’ to help settle this issue. Essentially the approach is to treat the hunt as two separate ‘supplies’, namely:
A single supply of the hunting experience, which includes things like a helicopter trip to the hunting ground, accommodation, food, guiding services and firearm usage; and
A separate supply of souvenir animal parts or a hunting souvenir.
GST is payable on the hunting experience supply, while a portion of the supply of the ‘souvenir’ may be zero-rated for GST, meaning the GST rate for this supply is 0%. Getting this clear is obviously quite vital if you’re a guide deciding how much to charge your clients.
How to work out the GST payable?
IR has taken the view that the portion of the hunt which relates to the animal parts (zero-rated for GST) rather than the hunting experience (15% GST) is higher for larger, more unique animals.
To give clarity, IR has adopted the Safari Club International (SCI) scale. The larger the animal and higher the SCI score, the higher the percentage of the hunt fee that can be zero-rated. Here’s the table IR are using to apportion the value of hunt fees:
There are certain other related rules to be aware of to enable this zero-rating to occur, including a time limit between the supply of the hunt and the export of the trophy. For further advice regarding this or other tax or accounting matters, please get in touch with me at firstname.lastname@example.org
Disclaimer – This information is generic and does not constitute tax advice and further advice should be sought before relying on this information for business decisions.