High Court Finds Mariner Has Permanent Place of Abode in New Zealand

This note summarizes the New Zealand High Court decision in Commissioner of Inland Revenue v. Van Uden, which found that a master mariner who was at sea for approximately eight months each year had a permanent place of abode in New Zealand. He was therefore a New Zealand tax resident, who was required to pay tax in New Zealand on his foreign sourced employment income and interests in foreign investment funds, including his employer’s contributions made on his behalf to its employee superannuation fund.