E tū / CICTAR — Transparency and Corporate Tax Reforms in Aged Residential Care Funding (2025)
E tū and Centre for International Corporate Tax Accountability and Research (CICTAR)
Publisher: E tū / CICTAR
Sector evidence
Sector body
2026-10-09
Next review not yet scheduled
New Zealand
High confidence
verified
SNZ editorial review
Evidence boundary: Joint union/tax-accountability research published 5 May 2025; 21 physical pages, with original June 2026 capture label. Company analysis covers a decade ending December 2024. Accounting tax expense and cash tax payments are different measures. Estimates and advocacy recommendations are attributed to the authors; Bupa’s response and the explicit no-illegality disclaimer are retained. This is not an official tax determination or proof of current funding/tax reform.
Short Answer
Edward Miller’s joint E tū/CICTAR report advocates greater transparency over aged residential care public funding and corporate tax arrangements, drawing on company financial statements and a Bupa New Zealand case study.
Key Points
- •CICTAR’s listing dates publication to 5 May 2025. The original has 21 physical pages and is prepared by Edward Miller with E tū; its contents include the company response and references (physical pp. 2, 17–21).
- •The authors argue that privately held providers’ financial filings do not consistently disclose their ARC public funding, while listed-provider notes provide some subsidy data. They propose a public funding database, not an already operating one (printed pp. 5–6, 15).
- •For Bupa Care Services New Zealand Limited over the decade to 31 December 2024, the authors calculate $292.7 million of cumulative pre-tax profit and $11.6 million of net income tax expense, about 4%. These are accounting measures (printed p. 11).
- •The same report gives cash tax payments of $24.9 million over that decade, about 8% of pre-tax profit. The roughly $12 million tax-expense headline should not be relabelled as the total cash tax paid (printed p. 11).
- •The authors estimate that intercompany interest reduced taxable income by $150.6 million, with a possible $27.1 million revenue effect under their method. This is an attributed estimate, not an Inland Revenue assessment (printed pp. 12–14).
- •Recommendations cover funding disclosure, reviewing capital-gains treatment, considering an interest-deduction limit alongside thin-capitalisation rules, and exploring public as well as private provision. They are proposals, not adopted law (printed p. 15).
Full Summary & Notes
Edward Miller’s joint E tū/CICTAR report advocates greater transparency over aged residential care public funding and corporate tax arrangements, drawing on company financial statements and a Bupa New Zealand case study. It compares listed-provider disclosures with privately held providers and proposes a public funding database and tax-policy review. The original distinguishes accounting tax expense from cash tax payments and includes Bupa’s response that it complies with tax law and prices related-party transactions at arm’s length. These are attributed research claims and policy proposals, with no allegation of illegality, rather than an official tax finding or enacted reform.
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