Giving Bookkeepers a Voice: NZQBA Submits Feedback on Overseas Software Payments
From Microsoft 365 and ChatGPT to industry-specific software subscriptions, overseas software payments are now part of everyday business. But are the tax rules and guidance practical for the people processing those transactions? That’s the question NZQBA has raised in our latest submission to Inland Revenue.
On 30 October 2026, the New Zealand Qualified Bookkeepers Association (NZQBA) submitted its response to Inland Revenue’s draft Interpretation Guideline, Income Tax – Non-resident software suppliers’ payments derived from New Zealand (PUB00266).
It might sound like a particularly technical topic, and in many ways it is. But behind the international tax terminology is something Bookkeepers deal with almost every day: processing payments for software subscriptions purchased from overseas suppliers.
And that’s exactly why we felt it was important for the Bookkeeper perspective to be represented.
Why did NZQBA make a submission?
The way New Zealand businesses purchase and use software has changed enormously.
Cloud-based accounting platforms, document management systems, customer relationship management tools, AI subscriptions and industry-specific applications are now routine business expenses.
But the guidance covering how payments to overseas software suppliers are treated for income tax purposes dates back to 2003.
Inland Revenue has been working to modernise that guidance, including recognising cloud-based software arrangements and the different ways software and related services are supplied.
We welcome that work.
However, while the technical interpretation is important, we wanted to make sure the final guidance also considers the people who are actually processing these transactions.
Because what makes sense in a technical tax document doesn’t always translate easily into day-to-day bookkeeping.
The reality of bookkeeping looks a little different
A Bookkeeper doesn’t necessarily receive a detailed contract or complete invoice when a business purchases software.
More often, they might see a transaction appear in a bank feed, a credit-card payment or an email confirmation forwarded into Hubdoc or another document management system.
Sometimes the business owner has already signed up and started paying for the subscription before the Bookkeeper knows anything about it.
And sometimes that subscription isn’t discovered until six or twelve months later.
The Bookkeeper then needs to establish what the payment relates to, whether it is a genuine business expense, what documentation is available and whether anything about the arrangement needs further attention.
That’s why one of our key recommendations is that ordinary software subscriptions should be straightforward to recognise and process, without every transaction becoming a research project.
We have suggested that Inland Revenue consider a practical benchmark of approximately 15 minutes for an initial check of a routine subscription.
Not as an exemption from tax obligations, but as a way of encouraging guidance that is genuinely usable in a small-business environment.
What have we asked Inland Revenue to consider?
Our submission doesn’t challenge the technical interpretation of international tax law. Instead, it focuses on making that guidance more accessible and practical for Bookkeepers and small businesses.
We’ve recommended several improvements, including:
- A simple checklist or decision tree
Something that helps a Bookkeeper identify an ordinary software subscription, understand what information might be missing and recognise when further investigation or specialist advice is needed.
- Clearer guidance on everyday subscriptions
We’d like to see more relatable examples involving commonly used products such as Microsoft 365, Google Workspace, ChatGPT and Claude, alongside industry-specific software.
These examples would help explain the principles, rather than suggesting that a particular product or brand always receives the same tax treatment.
- Practical guidance on documentation
One of the biggest frustrations for Bookkeepers is obtaining invoices and billing information from overseas software providers.
Often, invoices are locked inside supplier portals that only the business owner can access.
We’ve asked Inland Revenue to consider what documentation is reasonably required and how recurring subscriptions can be managed without unnecessary administration.
- Clearer explanations of when something needs further attention
Not every overseas software payment creates a complicated international tax issue.
But some arrangements, such as customised software development, implementation services or rights to commercially exploit software, may require a closer look.
We want Bookkeepers to be able to recognise those situations without needing to become international tax specialists themselves.
- Examples that reflect what actually happens
We’ve also recommended examples covering situations such as a small trades business paying for overseas job-management software, or a Bookkeeper discovering an unfamiliar subscription months after payments began.
These are the sorts of scenarios that make guidance useful in practice.
Why being the voice of Bookkeepers matters
This submission is about more than overseas software payments.
It’s about ensuring the Bookkeeper perspective is included when guidance, policy and regulatory decisions are being developed.
Bookkeepers play a vital role in New Zealand’s business community. They help businesses maintain accurate financial records, manage day-to-day transactions, meet compliance obligations and understand what’s happening with their finances.
They are often the first people to notice when something doesn’t look right, when information is missing or when a client may need additional advice.
That practical experience deserves a place in conversations about how New Zealand’s tax system operates.
At NZQBA, we believe advocacy isn’t simply about responding when something directly affects the bookkeeping profession. It’s also about contributing to decisions that affect the businesses our members support.
We want Inland Revenue and other decision-makers to understand not just what the rules say, but how those rules work when applied to real businesses, real transactions and real bookkeeping practices.
And importantly, we want to make sure Bookkeepers are recognised as valuable contributors to those discussions.
A big thank you to our contributors
One of the most valuable parts of preparing these submissions is the knowledge and experience our members bring to the table.
We’d like to give a special thank you to:
Their contributions helped us strengthen the submission with practical examples, real-world challenges and recommendations grounded in everyday bookkeeping.
These are exactly the insights that make NZQBA’s advocacy stronger.
This is what happens when we bring the knowledge of our bookkeeping community together and use it to help shape the conversations that matter.
What’s next?
Our submission has now been lodged with Inland Revenue, and we’ll be following the consultation as the guidance is finalised.
We don’t expect every recommendation to be adopted, but we do believe it’s important that the practical realities of bookkeeping are considered alongside the technical tax interpretation.
This is also part of our wider commitment to representing Bookkeepers in conversations about tax administration, compliance, professional recognition and the future of the profession.
Because the more Bookkeepers are involved in these discussions, the better the opportunity to develop guidance and systems that work for everyone.
Bookkeepers have an important voice. At NZQBA, we’re committed to making sure it’s heard.
Supporting Bookkeepers, Building Community.
Read our submission
You can read NZQBA’s full submission on PUB00266 here:
For further information about the consultation, visit Inland Revenue’s Tax Policy website.
