In certain situations, Inland Revenue (IR) may allow taxpayers to use tax pooling outside the standard 75-day window following their terminal tax date. This article provides a template and guidance for submitting a request to IR.
This typically applies to cases involving reassessments, voluntary disclosures, or where the Commissioner exercises discretion.
⚠️ Important: IR reserves the right to refuse the use of tax pooling. The taxpayer must meet Inland Revenue’s criteria in order to be eligible. The template below is provided as a suggestion only and should be submitted at the judgment of the client’s agent.
When to Use This Template
You may request discretion to use tax pooling if:
- IR has issued correspondence for a voluntary disclosure, and you would like to request discretion to use pooling
- You are outside the standard pooling window but meet the criteria for discretionary approval.
- You are acting on behalf of a client who has incurred additional tax due to late filing, incorrect advice, or other exceptional circumstances.
Template Message
Subject: Request for Discretion to Use Tax Pooling – [Taxpayer Name], IRD: [IRD Number]
To: Inland Revenue – Tax Pooling Team
From: [Your Name], [Your Firm or Role]
Date: [Insert Date]Kia ora,
I am writing to formally request the Commissioner’s discretion to allow the use of tax pooling for the following taxpayer:
- Taxpayer Name: [Insert Name]
- IRD Number: [Insert Number]
- Tax Type: [Income Tax or RWT/DWT]
- Tax Period: [Insert Period]
- Amount of Tax: [Insert Amount]
This request relates to a situation where the taxpayer has incurred additional tax due to [voluntary disclosure / reassessment / late filing], and we are seeking approval to use tax pooling outside the standard 75-day window.
In support of this request, we confirm that the taxpayer meets the three-part test outlined in RP 17B(9)-(10):
- Circumstances beyond the taxpayer’s control: [Brief explanation, e.g., incorrect advice, illness, system error]
- Reasonable justification or excuse: [Explain why the return was not filed on time]
- Good compliance history: [Confirm filing and payment compliance for the two prior income years]
We believe this situation aligns with the principles outlined in the Commissioner's guidance and recent updates to discretionary policy. We respectfully request that the Commissioner consider this application and allow the use of tax pooling to satisfy the liability.
Supporting documentation is attached for your review.
Please let us know if further documentation or clarification is required.
Ngā mihi,
[Your Full Name]
[Your Contact Information]
[Your Position/Firm Name]
Tips for Submission
- Attach relevant correspondence (e.g., reassessment notice or voluntary disclosure confirmation).
- Include a summary of the taxpayer’s compliance history.
- Be clear and concise in your justification.
- Submit the request promptly—IR allows 60 days from the date of correspondence to use tax pooling.