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Aniston Inger-Holland

She/herSolicitor
About

Aniston is a tax lawyer who advises asset managers, financial institutions, multinational corporates, family offices and high-net-worth individuals on all aspects of New Zealand taxation, with a focus on complex cross-border corporate and investment fund structuring.

Her work includes advising on tax-efficient structures for inbound and outbound investment funds involving New Zealand's portfolio investment entity (PIE), foreign investment fund (FIF) and Active Investor Plus (AIP) regimes. She also advises on fund structures in connection with feeder funds and fund hosting. She has also advised funds in relation to infrastructure, energy and forestry investments.

She also advises clients on corporate tax structuring, including in connection with their acquisitions, pre-transaction restructures, capital raises and international expansions.

Aniston provides detailed and comprehensive advice on international tax (including transfer pricing, thin capitalisation, Pillar 2 and permanent establishment risks), indirect taxes, fringe benefit tax and other employment-related taxes, and contentious tax matters.

Professional QualificationsBarrister and Solicitor of the High Court of New Zealand, 2025
Education
  • University of Auckland, Bachelor of Laws
  • University of Auckland, Bachelor of Commerce (Economics)
  • University of Auckland, Diploma in Languages (Italian and Russian)

EXPERIENCE

  • Acted for a UK-headquartered international asset manager on the tax aspects of the establishment of a first-of-its kind infrastructure fund compliant with New Zealand’s residency-by-investment Active Investor Plus (AIP) visa regime.
  • Advises various Australian asset managers on the establishment of New Zealand-based portfolio investment entity feeder funds, designed to invest offshore into Australian managed investment trusts.
  • Advises various investment managers and trustees on the impact of New Zealand GST policy changes and the impact on the treatment of fees charged in relation to funds. This included assisting clients with submissions to the New Zealand Government.
  • Acted for New Zealand qualifying recognised overseas pension (QROPS) provider on the acquisition of a superannuation scheme. Aniston also advises QROPS providers and asset managers on QROPS scheme tax rules.
  • Advised a New Zealand pension fund on forestry acquisitions by a portfolio investment entity, including consideration of the PIE regime, New Zealand's forestry tax and emissions regime, and GST considerations.
  • Represented a global asset manager on the negotiation of its tax pooling investment fund arrangement with a New Zealand tax pooling intermediary.
  • Advises warranty and indemnity insurers across the Asia-Pacific region on the provision of warranty and indemnity insurance for large-scale New Zealand and cross-border transactions.
  • Assisted a large multinational enterprise on the New Zealand tax aspects in relation to its pre-transaction global separation. This matter included advising on the New Zealand and international tax implications of entity and asset transfers, distributions and share issuances, debt arrangements, intercompany balance offsets, and cross-border cash repatriation.
Languages
  • English

Additional Information

  • Actively involved in the firm's pro bono programme with the Auckland Community Law Centre
  • She drove the firm's partnership with Auckland Law School's Coffee Mates mentoring programme, and student mooting initiatives.

Memberships

  • American Chamber of Commerce in New Zealand NextGen Committee
  • Young International Fiscal Association Network
  • New Zealand Law Society
  • New Zealand Centre for Taxation

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