1. Future of Charities and Tax – a Māori Perspective
Mark Lash
Partner, Deloitte
April 2019

2. Iwi Group Structure and key roles
Post Settlement
Governance Entity
Investment Trust
(Registered Charity)
Primary Role –
Governance and
strategic direction
Primary role
Protect and grow the
putea
/ commercial assets
Iwi Development
Trust (
Registered Charity
still
Primary Role: Social services,
community and cultural etc
Ownership
Control / appointment
Iwi
Asset Holding Company
for Maori Fisheries Act

3. Tax Funds flows IRD Iwi Complying Trust Charitable Trust
Charitable distributions
to Iwi
Non charitable
distributions to
Iwi
Complying Trust
Charitable Trust
Company
Charitable Company
Limited Partnership
Post Settlement
Governance Entity
(Maori Authority)
IRD
Dividend Income (
including
Imputation Credits)
Dividend Income (including
Selected Portfolio
Investments
Taxable Commercial
Entities
Charitable
Commercial
Subsidiaries
(if any)
Interest on loan
Investment Trust
(Registered Charity)
Iwi Development
Trust
Distribution Income
(including Maori
Aut
hority Tax Credits)
Distribution (including
Maori Authority Tax
Credits)
Maori Authority
Tax refund
Asset Holding
Charity to charity
distributions
Limited
Partnerships
(if any)

4. Some Perspectives Understanding the kaupapa of Māori organisations
Ostensibly charitable but Crown requirements for settling entity
He tangata – it is about the people
Separation of entities and use of charities – dividing up roles
Purposes / kaupapa
People, Tikanga, Environment
Deep understanding of what is necessary to make a difference
Taxation of business income
Risks to delivering outcomes if tax changes reduce the resources available
History of Crown failing māori

5. Some Perspectives (cont)
Opportunities to positively enhance outcomes
Refundability of imputation credits
remove the distortion for specific investments or need for specific structures
increase the funding available to the sector, māori and non-māori
Distribution tax
Needs to acknowledge an inter-generational view
Impact of an overly onerous distribution requirement on the ability to build putea / restore the asset base
Delivery of outcomes through activities v distributions in $
Charites compliance and the role of DIA Charities and advisors

6. Kia Ora

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