GIVING A HELPING HANII JASIIN . II I THE NEW INITIATIVE 2 THE NEW ZEALAND INITIATIVE The New Zealand Initiative is an independent public policy think tank supported by chief executives of major New Zealand businesses. We believe in evidence-based policy and are committed to developing policies that work for all New Zealanders. Our mission is to help build a better, stronger New Zealand. We are taking the initiative to promote a prosperous, free and fair society with a competitive, open and dynamic economy. We develop and contribute bold ideas that will have a profound, positive, longterm impact. 2 ABOUT THE AUTHOR ACKNOWLEDGEMENTS Jason Krupp is a The author wishes to acknowledge Research Fellow at and thank all those who participated The New Zealand in interviews, reviewed or commented Initiative, and has on this report. Special thanks are published reports due to Susan Barker, whose help on housing afford- and guidance proved invaluable, ability, the impact of the compact and to Mark Maciolek for the work planning ideology on cities, and he put into this project while resources. He is also a regular con- completing an internship at The tributor to many of New Zealand’s New Zealand Initiative. Any errors leading media titles. Before joining or omissions remain the sole the Initiative, Jason was a business responsibility of the author. reporter at Fairfax Media, covering financial markets and the corporate sector for the Dominion Post and Business Day. He has also lived and worked in Hong Kong and South Africa. GIVING CHARITIES A HELPING HAND 3 GIVING CHARITIES A HELPING HAND C harities play an important role on income, the ability to claim donee But while the core definition of in New Zealand, delivering a status thereby allowing donors to what is and is not a charity has range of social services to a claim a tax credit for their donations, been in existence for hundreds of number of communities and causes and a fringe benefit tax exemption years, the rules governing charities that would be difficult to emulate on non-cash benefits paid to employees. have changed dramatically in on a private or a state-run basis. New Zealand. Over the past eight According to official figures, there These privileges provide a significant years government has increased are over 26,000 registered charities tailwind for groups that perform the level of legislative control of the active in the country, with a collec- charitable work in society, which charities sector by: tive income of almost $16 billion in is why it is important to only confer the 2013 tax year. In 2010, charities these privileges upon genuine charities, active in New Zealand reported and not to those looking to avoid an average of 1.1 million volunteer taxes that they would otherwise hours each week (equivalent to have to pay as a private individual or 27,500 fulltime staff), and just over group. This is why there is a plethora 4 million paid hours over the same of laws regulating the sector, and period (equivalent to 102,500 full- a regulator tasked with conferring time staff). The benefits provided and removing charitable status by these groups are recognised by according to a long-standing the government, which not only definition of charitable purpose funds many of their activities, but that has stood for at least four also confers certain privileges upon centuries.3 1 2 them. These include tax exemption  passing legislation to establish a register of charitable entities and a regulator outside of government,  replacing the autonomous regulator after four years,  imposing financial reporting requirements on all registered charities,  stipulating strict tax implications for groups that lose charitable status, and  committing to a regulatory review on which it subsequently reneged. 1 “Charities Services,” Charity Services, accessed 29 April, 2015, https://www.charities.govt.nz/ 2 Donald Poirier, Charity Law in New Zealand (Wellington: New Zealand Government, Department of Internal Affairs, 2013), p.69. 3 “Purposes Beneficial to the Community,” Charity Services, accessed 29 April, 2015, https://www.charities.govt.nz/apply-for-registration/rules-and-the-charities-act-2005/purposes -beneficial-to-the-community 3 4 THE NEW ZEALAND INITIATIVE Figure 1: Overall trust in charities rightfully due. This will limit the TRUST IN CHARITIES: AVERAGE SCORE amount of work they can perform in communities, damaging the I trust charities 10 completely 9 perception of the sector in the eyes of the public. 8 7 6.54 6.45 6 5.82 6.00 environment where, at the margin, 4 New Zealand gets it wrong on both 3 counts. On one hand, a strict 2 interpretation of what is and isn’t a 1 charitable purpose excludes many 2008 2010 2012 2014 Source: Department of Internal Affairs, Public Trust and Confidence in Charities, 2014 A number of these changes have with charities, and not the nature of been made with the aim of boosting the regulatory relationship between public trust in the charities sector. charities and the regulator. This is an important consideration since much charity funding is provided As such, members of the public are by the general public and government, more likely to be influenced by and it follows that excessive levels their experience with so-called of fraud are likely to impact on these ‘chuggers’ (third party charity funding streams to the detriment of agents who solicit donations in legitimate charities and the communities public spaces) and door-to-door and causes they serve. solicitation rather than the government’s oversight of the sector. Unfortunately, the changes appear charities from attaining registered status, or makes it very difficult. On the other, a longstanding charity law allows an exemption from income tax for charities’ commercial arms, allowing them to avoid paying taxes on profits that are not put to charitable purposes but retained within the business. In short, the recent reforms have changed the oversight of the sector without really assessing whether the new arrangements have achieved the optimal outcome of maximising transparency, efficacy and trust. to have fallen short of their intended Nevertheless, it is also obvious that mark. According to a biennial survey, the regulator has an influence on TALE OF TWO REGULATORS overall trust in the charities sector the public’s trust in the sector by In order to hone in on the issues as at 2014 has shown only a marginal granting or removing charitable improvement after plummeting to status and by vetting the financial the lowest levels on record in 2012. 4 records of charities. In the case Readers should of course be cautious of the former, the regulator must about drawing too strong a conclusion walk a very fine line. Setting the about the regulatory settings from bar too low will allow groups and the Horizon poll. The survey only individuals to qualify for charita- focused on the public’s interaction ble privileges they are not entitled to, damaging public trust in the sector. Setting the bar too high will disqualify many legitimate charities from receiving privileges they are 4 spate of regulatory changes over the last 12 years has resulted in an 5 I don't trust charities at all This research note argues that the with the current regulatory arrangements it is worthwhile to explain how the framework came about. Until the mid-2000s the charities sector was largely governed by Inland Revenue, through its administration of the charitable income tax exemptions. This changed when the Labour-led government passed the Charities Act 2005 (the Act), establishing 4 Department of Internal Affairs, Public Trust and Confidence in Charities, May 2014, p.8 GIVING CHARITIES A HELPING HAND 5 the Charities Commission, an autonomous Crown entity that was tasked with regulating the sector. One of the commission’s primary jobs was to set up and maintain a charity register, a tool intended to bolster the public’s trust. The "...the regulator has an influence on the public’s trust in the sector by granting or removing charitable status and by vetting the financial records of charities." impetus for this change had come from the sector itself, which pushed The Charities Register opened on mission, handing oversight of for a register to be established 1 February 2007, and charities had the sector to the Department of so that so-called ‘bad’ charities until 1 July 2008 to register with Internal Affairs (DIA), under a could be eliminated, and the public the commission before the new new unit called Charities Services. could have confidence in those that tax provisions came into force. In response to concerns raised remained. As part of this change, However, by 2007, the Charities by the sector about the indepen- registration became a prerequisite Commission had accumulated a for an organisation to access the significant backlog of applications. charitable exemptions from income tax. In 2008, the National Party was voted was established as an independent dence of the charities regulator, 6 the Charities Registration Board into power. The Charities Commission three-member panel to make decisions Around the same time, the Labour came under significant pressure to regarding registered charitable status government, as part of the confi- reduce the backlog, and some in the autonomously from government. dence and supply agreement with sector believe that the regulator The move to disestablish the Charities United Future, removed the cap responded by registering charities Commission was part of a broad on charitable donations by indi- en masse and flagging them for later state sector consolidation, which viduals, which was set at $1890. investigation. That over 25,000 brought a number of government This allowed individuals to donate organisations were added to the functions in-house to reduce cost.9 any amount to charity, subject to register by the end of the 2010 In the same year the government their maximum income, and claim financial year supports this view. reneged on the first principles 7 a third back as a tax rebate. This review promise, with Community lifted private charitable giving by In 2010, the government committed and Voluntary Sector Minister Jo about $95 million a year to $193 to a first principles review of the Goodhew saying the “widening” of million, and raised the average Act, looking at the fundamental the definition of charitable purpose amount for rebates from $256 to concepts underpinning the legislation would have “fiscal consequences”.10 $504 per donor per year before to assess whether these were fit for Other issues that might have been the rule change. In addition, the purpose.8 But just as the regulatory addressed by such a review, such as 5% deduction limit that applied to structure was getting embedded in functioning of the regulatory struc- companies and Maori authorities 2012, the National-led government ture, do not appear to have been was also removed.5 disestablished the Charities Com- considered. 5 Michael Gousmett, “The History of Charitable Purpose Tax Concessions in New Zealand: Part 1,” New Zealand Journal of Taxation Law and Policy 10 (June 2013): 170. 6 National Party, “Charities Commission Chokes on Backlog,” accessed 1 May 2015, https://www.national.org.nz/news/news/media-releases/ detail/2007/10/11/charities-commission-chokes-on-backlog. 7 Elizabeth Margaret Bang MNZM JP, (Affidavit, 14 June, 2014) NZHC 3200 New Zealand High Court, 9. 8 Tariana Turia, “Charities Commission Annual General Meeting,” Official Website of the New Zealand Government, accessed 29 April 2015, http://www.beehive.govt.nz/speech/charities-commission-annual-general-meeting-0. 9 “New Zealand Public Health and Disability Amendment Bill, Mental Health Commission Amendment Bill, Charities Amendment Bill (No 2) 10 — Third Readings,” New Zealand Parliament Hansard and Journals, accessed 29 April 2015, http://www.parliament.nz/en-nz/pb/debates/ debates/50HansD_20120530_00000028/new-zealand-public-health-and-disability-amendment-bill. Jo Goodhew, “No review of the Charities Act at this time,” Official Website of the New Zealand Government, accessed 29 April 2015, http://beehive.govt.nz/release/no-review-charities-act-time. 5 6 THE NEW ZEALAND INITIATIVE Registration Board opted to take a Act 2013 and the Financial Reporting SLEDGEHAMMER DEFINITION Amendment Act 2014, which require The Act defines charitable purpose of what is, and is not, a charitable all registered charities to file annual as “every charitable purpose, whether activity. The Sensible Sentencing returns with the regulator, and the it relates to the relief of poverty, the Trust, for example, was forced to new tax rules for charities that lose advancement of education or religion, split its operations into a lobbying their registered status represented or any other matter beneficial to unit and a separate victim support just over a decade of legislative change, the community”.12 Importantly, a unit to maintain the charitable with much of it hardly given time charitable purpose must satisfy the status of the latter because its advocacy to bed in before the next tranche of public benefit requirement, meaning for tough criminal sentences was reform was enacted. This left little that purposes must operate for the deemed to be political (and hence time left for reflection and careful benefit of the public and not private non-charitable) even though the consideration of the unintended interests in order to be considered lobbying activity was ancillary to the consequences that might occur. charitable. Allowance is given for trust’s main charitable purposes.13 groups that have non-charitable Similarly, the National Council of purposes, provided those purposes Women of New Zealand was stripped are ancillary to the main charitable of its charitable status because its purpose. work making submissions on The passing of the Financial Reporting 11 very narrow, black and white view Parliamentary Bills in furtherance While this may seem like an easy of its charitable purposes was distinction in theory, in practice deemed to be political advocacy it is much harder. The Charities (see case study on page 11). Commission and the Charities 11 Income Tax Act 2007, HR 12. 12 Charities Act (2005), section 5 13 Marty Sharpe, “Charity rejection splits Sensible Sentencing Trust,” The Dominion Post, accessed 29 April 2015, http://www.stuff.co.nz/national/3867650/Charity-rejection -splits-Sensible-Sentencing-Trust. 6 GIVING CHARITIES A HELPING HAND 7 "Since Charities Services is not resourced to actively monitor all 26,000 charities on its register, and instead appears to only inspect charities that come to its attention, this has created the perverse situation where legitimate charities may be reluctant to change or update their constitutions for fear of coming to the regulator’s attention." Other charities to fall foul of the performance programme.15 In Many charities struggle to attain strict interpretation of charitable reviewing the decision, a legal charitable status because of the purposes include Swimming NZ. commentator noted that the decision strict interpretation of charitable The national organisation was would have significant consequences purpose. Just Zilch, for example, accepted into the charities register for sport in the country, as over gathers food from shops and in 2008 for its work promoting 7,000 sports organisations were restaurants that would otherwise swim programmes, competitions reliant on their registration for be thrown away and gives these as well as a programme for top “access to funding and other goods to the public from its retail athletes in the sport. Yet amendments benefits which are only available premises in Palmerston North. Yet to the Swimming NZ constitution to charities. Losing these benefits the group struggled for two years in 2012 came under the scrutiny could leave many sports without to get registered status because it of the Charities Registration Board, the much needed income to run could not prove to DIA that those which ruled that while the or- sport in our communities”. Since who made use of its services were ganisation performed charitable Charities Services is not resourced destitute, and hence it was deemed work, the high performance and to actively monitor all 26,000 to confer private benefits to some. competition programmes were not charities on its register, and instead Just Zilch Managing Director Re- charitable ends in themselves. As appears to only inspect charities becca Culver said this was a delib- a result, Swimming NZ was dereg- that come to its attention, this erate choice by the charity to catch istered in 2014, despite the Act has created the perverse situation people who fell through the cracks, specifically stating that sport may where legitimate charities may be such asset-rich but cashflow-poor be a charitable purpose if it is the reluctant to change or update their middleclass households who fell on means through which a charitable constitutions for fear of coming to hard times but did not qualify for purpose is pursued, and despite the regulator’s attention. state support.17 14 16 the ancillary nature of the top 14 Maria Clarke, “Is sport charitable anymore?” New Zealand Law Society, accessed 29 April 2015, https://www.lawsociety.org.nz/lawtalk/issue-862/is-sport-charitable-any-more 15 Charities Act (2005), section 5(2A). 16 Maria Clarke, “Is sport charitable anymore?” 17 Rebecca Culver, personal interview, 8 April, 2015. 7 8 THE NEW ZEALAND INITIATIVE The legislation dictates that the However, the new rules can be The high threshold of filing proceed- charities regulator has to notify a problematic when coupled with the ings at the High Court combined group being declined entry to, or uncompromising interpretation of with the limited scope for appeal removed from, the register, and charitable purpose, and the nature have a chilling effect on the sector. why. The group can object to the of the appeal process stipulated It limits the number of legitimate decision by making a written sub- by law. charities able to gain or maintain mission to the charities regulator, registration. This can mean not who will then consider the case and Given that the regulator does not only loss of income tax exemp- make a final decision. The parties conduct hearings, charities do not tion, but also funding, as funders that object to the charities regulator’s have the ability to have an oral increasingly restrict their support decision can challenge it at the High hearing of evidence to demonstrate to registered charitable entities. Court. However the requirement whether their purposes are charitable. More concerning is that it creates a to file proceedings in the High Court Importantly, the regulator is not situation whereby many legitimate sets a very high threshold, one that bound by the rules of evidence charities are forced to shut down many charities will struggle to when reaching its decision. As rather than undergo a costly and meet given the costs, which have such, a charity will not necessarily uncertain appeal process. to be self-funded as is shown in the know what evidence the regulator National Council of Women case has considered or ignored, or study. More critically, the appeal indeed what weight it may have right is currently being interpreted placed on any particular piece of as an appeal on the record, rather evidence. This can be problematic than a fresh hearing, as noted by as the regulator is increasingly reliant charities lawyer Susan Barker. on searches of official websites to 18 19 assess charitable purpose, as was For charities that lose their charitable revealed when Greenpeace chal- status, the consequences can be lenged its removal from the chari- severe. Recent changes to the Income ties register in the Supreme Court.21 Tax Act 2007 state that any group Relying on online information removed from the charity register could result in the regulator finding is due to pay tax on any net assets material that is out of date, out of held 12 months after the last appeal context, or simply incorrect. Yet has been exhausted, as well as tax charities are denied the opportuni- on any income earned after that ty to test any of the assumptions, or period.20 In principle, these new tax the decisions made regarding what rules are appropriate, given that material is considered, disregarded the tax exemption privileges should or overlooked. thE TAX THAT GOT AWAY These regulatory settings, which apply significant stricture on small operators in the sector, could be explained by the economic environment where the government is concerned about maintaining tax revenue. After all, from a fiscal perspective the state foregoes an estimated $400 million in tax earnings by allowing charities to claim exemptions, excluding tax deductions by individual and corporate donors.22 Unfortunately the focus appears to have unduly fallen on small operators, even as significant sums of profit in the sector remain untaxed. only be granted to legitimate charities. 18 Charities Act 2005, ss 32-36. 19 Ibid., ss 59-61. 20 “New rules for deregistered charities,” Inland Revenue, accessed 29 April, 2015, https://www.ird.govt.nz/technical-tax/legislation/2014/2014-39/2014-39-deregistered-charities/. 21 Greenpeace of New Zealand Incorporated v Charities Commission. 2014 NZSC 105. Supreme Court of New Zealand. 22 Phil Taylor, “Please give carefully,” New Zealand Herald, accessed 29 April 2015, 8 http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=10893671 GIVING CHARITIES A HELPING HAND 9 This is due to a law that dates back more than 100 years, allowing groups that undertake for-profit activities for charitable purposes to access the charitable income tax exemptions. These groups can also assume the same limited liability status as private firms, and retain a portion of their earnings within the business with little oversight by "This creates the potential for distortions in the market, allowing private businesses to accumulate large cash reserves under the tax exemptions afforded to charities that can be used to unfairly compete against private operators." the charities regulator or the government. The effect has been best profits, with only 20% of the $161 excluding Ngai Tahu.26 To date, illustrated by independent charity million earned in the 2014 financial Charities Services has provided little researcher Michael Gousmett, who year paid to iwi as a dividend. This to no oversight over how much of has focused on how Ngai Tahu creates the potential for distortions these funds are directed towards have legally structured their affairs in the market, allowing private their respective charities, what under these rules to best benefit businesses to accumulate large cash the charities do with these funds, the South Island tribe, albeit to the reserves under the tax exemptions and how much is retained by the detriment of the government’s tax afforded to charities that can be businesses (although the extent to take.23 His research shows that as used to unfairly compete against which this position may change of October 2014, Ngai Tahu Charitable private operators. Ngai Tahu under the new financial reporting Group had 37 active commercial units is hardly the only entity to take rules for registered charities, which (or members) claiming charitable advantage of these rules to exempt came into effect on 1 April 2015 status. The vast majority of these their commercial operations from remains to be seen). What is clear are commercial operations, active income tax. Other well-known is that, at a tax rate of 28%, the in multiple sectors of the economy organisations to have done this government has foregone an including fisheries, property and include breakfast cereal maker estimated $104 million in fiscal property development, finance, Sanitarium and hospitals such as revenue annually by allowing this agriculture and tourism. Many of Dunedin’s Mercy Hospital and legal arrangement to exist. these operations will be familiar Christchurch’s St. George’s Hospital. to the public, including Ngai Tahu Gousmett estimates there are 700 Property, Proseed New Zealand, limited liability companies on the Shotover Jet Limited, and Ngai Charities Register that generate Tahu Development Corporation. over $372 million in tax-exempt Critically, Gousmett notes that the profits and hold $3.6 billion in assets 24 25 law allows these business units to retain much of their untaxed 23 Michael Gousmett, “The failure of Ngai Tahu Holdings Corporation as a charitable entity,” New Zealand Centre for Political Research, accessed 29 April 2015, http://www.nzcpr.com/the-failure-of-ngai-tahu-holdings-corporation-as-a-charitable-entity/ 24 Ibid. 25 Susan Barker, “Are all charities equal?” p.41. 26 Michael Gousmett, “The failure of Ngai Tahu Holdings Corporation as a charitable entity” 9 10 THE NEW ZEALAND INITIATIVE REFORM THE LAWS OF GIVING highly costly and onerous for many taxing retained profits it would groups. For example, the Act could incentivise these firms to distribute Although the regulatory structure be amended to allow charities to more of their pre-tax earnings to governing the charitable sector has lodge a challenge at a District Court their relevant charities, thereby undergone significant change in level, with further appeal to the boosting the resources of the sector. the last decade, it is clear from the higher courts if needed. Furthermore, Charities Services must also ensure problem description above that further policymakers should instruct the that any significant distribution fine tuning of the policy structure District Court to review the case is assessed to ensure that it funds could significantly improve the on a de novo (from fresh) basis, as genuine charitable purposes. functioning of the sector. is done in the Environment Court, allowing affected parties to submit The first much needed change is evidence to support their case for a review of the Charities Act. This charitable status and cross-examine should not be limited to a review of the board on the decision that they the definition of charitable purpose, have reached. This would provide although such a review would allow significant relief to small charity policymakers to assess whether the operators, even under the current current definition is appropriate. definition of charitable purpose. In addition, the review might usefully examine whether religious Urgent reform of for-profit businesses and cultural institutions should owned by charities is also needed. continue to qualify for charitable The most simple and effective fix is status simply because they pursue to tax these organisations in the the goal of promoting religion and same way that private firms are culture. This is not to say that such taxed, while allowing unlimited institutions should not be considered, deductions on distributions made but the assessment criteria should to their relevant charities, as was be the same for all organisations proposed by Helen Clark’s government seeking the status of registered in 2001.27 The assets accumulated charities. by these businesses should not BUILDING BLOCKS OF TRUST It would be somewhat naïve to expect the policy changes proposed in this report to dramatically lift the public’s trust in the charity sector. This is governed by a number of factors that extend beyond the recommendations in this report, such as the conduct of charities when fund raising, the prevalence of fraud and so on. However, greater transparency, clearer rules and processes, and the removal of unfair advantage would go a long way to establishing strong regulatory foundations, allowing the charities sector to further perform the good work that society has come to expect. be subject to tax unless they are With respect to the charities register, stripped of their charitable status, charities must be allowed to chal- in which case the standard tax lenge the decision of the Charities process would apply. This policy Review Board at far lower level change would remove any unfair than the High Court, recognising tax advantage that charity-owned that this legal channel can prove businesses have over private for-profit firms. In addition, by 27 Michael Gousmett, “The History of Charitable Purpose Tax Concessions in New Zealand: 10 Part 1,” New Zealand Journal of Taxation Law and Policy, 10 (June 2013) p.170. GIVING CHARITIES A HELPING HAND 11 CASE STUDY: ENDANGERING KATE SHEPPARD'S LEGACY In 1896, the National Council of Women of New Zealand started out as a charitable organisation, with renowned suffragette Kate Sheppard as its first president. Over the next 109 years the group, which works for the betterment of women, children and the family, maintained its charitable status under the regulation of Inland Revenue. With the establishment of the Charities Commission, the council applied to become a registered charity. In June 2009, over a year after it had first submitted its application, the council’s application was accepted, with registration being backdated to 30 June 2008. At the time the application was accepted, the council was earmarked for subsequent investigation. The investigation ultimately resulted in the council’s deregistration in June 2010 on the basis that its work advocating for “changes in law, policy or decision of central government” was political and ancillary to its stated charitable purposes.28 Stripped of its registration, the charity became affected by a stigma and soon found it difficult to raise In January 2014, aided by pro bono funds from traditional sources that legal advice, the council challenged had a preference for supporting the decision not to backdate the registered charities. Unable to group’s charitable status in the substantively appeal the deregistration High Court. The council argued decision, in 2012 the council again that it was eligible to be regarded applied for registered status, and as a registered charity for the entire asked the Charities Registration period, that the Charities Registration Board to backdate the group’s reg- Board was empowered to backdate istered status to 2010 to avoid having its registered charitable status, and to pay taxes during the period it that it should not be liable to pay was deregistered. Then-president income tax for that period. 29 of the council, Elizabeth Bang, noted that the application “took literally The High Court found in favour hundreds of hours to prepare” on of the National Council of Women advice that the group would have of New Zealand, and ordered the no automatic right to submit new regulator to backdate the council’s evidence to the High Court should charity status to 2010, wiping clear it wish to appeal any decision on its the tax obligation. 31 The process reapplication.30 was not without its costs, racking up $90,000 in legal expenses. The charity’s bid was successful, Most of this was conducted on a even though its purposes, consti- pro bono basis by charities lawyer tution and activities had remained Susan Barker. Had this not been unchanged, and in April 2013 available, Bang said the council it was again accepted onto the would not have had the resources register. However, the council’s to challenge the regulator’s decision charitable status was only backdated in court. Nevertheless, the council to September 2012. As a result, still “faces the very real prospect National Council of Women of of closure as a direct result of the New Zealand faced a period from deregistration decision, even now”.32 June 2010 to September 2012 when it was not registered as a charity. IRD sought to impose income tax for this period of deregistration. of having done “something wrong”, 28 The National Council of Women of New Zealand Inc. v The Charities Registration Board (2014), New Zealand High Court NZHC 1297 (10 June 2014) 29 Affidavit of Elizabeth Margaret Bang MNZM JP (14 June 2014) CIV-2014-485-1017 p.1 30 Stet. p.5. 31 The National Council of Women of New Zealand Incorporated v The Charities Registration Board 2014, 14. 32 Bang (Affidavit 2014), 9. 11 w w w.nzinitiative.org.nz The New Zealand Initiative is an independent public policy think tank supported by chief executives of major New Zealand businesses. We believe in evidence-based policy and are committed to developing policies that work for all New Zealanders. Our mission is to help build a better, stronger New Zealand. We are taking the initiative to promote a prosperous, free and fair society with a competitive, open and dynamic economy. We develop and contribute bold ideas that will have a profound, positive, longterm impact. The New Zealand Initiative PO Box 10147 Wellington 6143