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Gift duty is to be abolished

25th August 2011

Gift duty has been a feature of New Zealand's law since 1885.  But it is about to be abolished.

Gift duty was originally intended to buttress the former estate duty regime by discouraging the gifting of assets prior to death.  While estate duty was repealed almost 19 years ago, gift duty was retained as an interim measure in the hope it would to limit tax avoidance and because it was viewed as providing some protection to creditors.

Many New Zealanders have underway a program of annual gifting whereby each year they make a gift to their trust, free of gift duty.  This is part of their planning to see that wealth which would otherwise be personally theirs is owned by their trust, for the protection that separate ownership brings. 

Last week Parliament passed amending legislation abolishing the liability to pay duty on a gift.  That law is likely to come into force on 1 October this year.  Once in force there will no limit upon the amount of money that can be gifted to a trust free of duty. 

This presents an opportunity

The abolition of gift duty will be relevant to you if you have transferred property to a trust and a debt is still owed to you by the trust in connection with the transfer.  Currently, the debt owed to you by the trust can be forgiven over time at a rate of $27,000 (per donor) for every 12 month period, without incurring any liability for gift duty.  Gifts of more than $27,000 in any 12 month period attract gift duty.  A gift statement must be signed every time a gift is made and, where the gift is made by way of a reduction or release of debt, a deed is also required.

Once the gift duty repeal comes into effect, you will have a choice to do one of three things with the remainder of the debt your trust owes you. 

One response will be to do no further gifting and leave in place the present remainder of the debt owing to you by your trust. 

A second response will be to gift-off in a single final gift the entire remaining debt balance owing to you.

The third possible response will be to continue on with a progressive gifting program of the type you have undertaken to date.

If you elect option two or three, no gift statement need be filed with Inland Revenue as has been the case until now, but a formal deed of gift will be necessary and the annual financial accounts of your trust must record the gift undertaken during the year concerned.

There are important implications to consider before making your election

Before you decide which of the three options you will elect to exercise when this new law comes into effect, you should take professional advice as to the implications of electing one of the various responses. 

Why?  Because there are significant considerations to take into account, including relationship property, creditor protection, income tax and welfare considerations.  In certain circumstances it may well be appropriate to continue with a regular gifting program (the third option we refer to above).

Each person or couple faced with this opportunity will place different weight upon the various considerations, depending upon their circumstances.  So it will not be a case of simply forgiving all the debt in a single action now (without specific advice on the point), as if a loose end was being tidied up.

So if you have a trust and it still owes a debt to you, we encourage you to take advice on this before making your election. 

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Joint Misadventures

22nd August 2011

Joint ventures are widely used in New Zealand business.  The size of our country and constraints on access to capital mean that this type of collaboration is often essential for business expansion.  A joint venture arrangement will typically involve each joint venture partner bringing their respective expertise and resources together for a common business purpose, often exploited through a new company owned by the joint venture partners. 

A recent decision of the Court of Appeal has highlighted the dangers for joint venture partners in expanding a joint venture business without final documentation or a considered eye for the future.  The case also serves as useful reminder for current or prospective joint venture partners of the obligations they may owe to each other even in the absence of formal corporate structures or contracts.   

Background

The joint venture business in this case started from a New Zealand company involved in commercialisation of the Habode portable home concept.  The two principal shareholders of the company were Mr Gibson (who provided design expertise) and Mr Curtis (who provided finance and marketing expertise). 

In 2004, the parties began with great gusto to document their intended arrangements for a New Zealand and international joint venture business.  But inertia soon set in.  Only a limited number of contracts were ever concluded and signed (primarily in relation to the New Zealand business) and the stuff of day-to-day business then took over.  Mr Gibson spent significant time in China developing a Habode prototype while Mr Curtis took care of business in New Zealand and began to explore licensing opportunities in Australia.  Additional Habode companies were incorporated by Mr Gibson and Mr Curtis in Hong Kong and by Mr Gibson in Australia. 

The wheels then started to fall off.  By 2006, the New Zealand business was facing cashflow difficulties and there were doubts about the solvency of Habode NZ.  This company was placed into liquidation by a group of unsecured creditors and the New Zealand business was swiftly brought to an end.  This also spelled the end of the business relationship between Mr Gibson and Mr Curtis.  

Undeterred, Mr Gibson picked up on developments in Australia and in short order secured a significant deal for the sale of a minority interest of the business in Australia.  This deal was secured using contacts who had previously dealt with Mr Curtis.  This windfall was in turn the impetus for Mr Curtis to bring the court action against Mr Gibson.   

What did the Court of Appeal decide? 

The general position under New Zealand law is that a joint venture arrangement of the nature established by Mr Gibson and Mr Curtis gives rise to fiduciary duties of loyalty, trust and confidence on each joint venture partner approaching the seriousness of those owed by a trustee to his/her beneficiaries.  A joint venture can exist if the parties are dependent on each other to make progress towards a common objective, regardless of whether all the necessary details have been agreed. 

The Court found that the formal corporate structure for New Zealand provided both a model for the Australian side of the business and a platform from which expansion into Australia could occur.  Although the arrangements for a joint venture company were never finalised in Australia (i.e. they never progressed beyond the incorporation of the company by Mr Gibson), the Court held that it was intended by the parties that a company would be used in Australia to market and distribute the Habode concept and that the ownership of that company would be owned equally by Mr Gibson and Mr Curtis. 

Upon termination of a joint venture, any assets of the joint venture, whether tangible or intangible, are held on trust for the former joint venture partners pending agreement between them on the wind up of the joint venture.  For this reason, the Court of Appeal held that information gained with respect to the business opportunity in Australia was gained during the course of the joint venture and constituted confidential information belonging to the joint venture. 

The net result was that Mr Gibson could not exploit any confidential information of the joint venture in Australia for his own benefit to the exclusion of Mr Curtis.  Mr Curtis was therefore entitled to a share of the profits made by Mr Gibson in Australia.  The case has been referred back to the High Court to decide the share of the profit that should be paid to Mr Curtis. 

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What's this current publicity about "trust-busting" and is your trust still worth having?

29th June 2011

Do family trusts still serve your best interests?

The answer in most cases will continue to be a very definite "Yes".  Many of us continue to want the flexibility a fully discretionary family trust provides. 

Our wish may be to manage the transfer between generations of wealth within a family using an ownership vehicle (the trust) which sees family wealth passing to the next generation in a sheltered manner.  It may also be to quite lawfully shelter assets from the claims of future creditors, future relationship property claimants and other third parties.

In years gone by income tax minimisation and death duty minimisation were major drivers for many clients to settle wealth on a trust.  Additionally, some people have been able to use a trust to shelter wealth from rest-home subsidy claw-back, in days when the Treasury was under less pressure than it is now.  We are now on notice that our wealth whatever/wherever it is will have to be used first to fund our old age care.

So while Government initiatives from time to time may adversely impact upon the degree to which trusts can be used to successfully shelter wealth, there remain good reasons for many to want to have wealth owned by a trust for their benefit and their family's benefit, and that is not likely to change in the foreseeable future. After all, trusts have been a feature of our legal system here in New Zealand for 170 years now and a feature of England's legal system for hundreds of years before 1840.

So why this current talk of "trust-busting?"

"Trust-busting" activity is being spoken of quite often in the media today.  What's that all about?

This expression is not entirely accurate, but essentially it is used to describe a wealth recovery effort that has been possible for many years.

Historically, people who sought unlawfully to avoid their legal obligations to the IRD or to their creditors or to an existing wife or partner by transferring personal wealth into a trust have always faced the possibility of that transfer being reversed by a Court on the basis that the wealth concerned should not have been transferred to the trust in the first place. That's not a new development.

Clearly there should be a recovery remedy if a person is shown to have impoverished himself or herself by transferring wealth into a trust (or into any other type of ownership vehicle) at a time when he or she is unable to pay their debts.  Current insolvency law provides a remedy for a creditor when that circumstance can be established.

Similarly, if a spouse transfers wealth across to a trust when his or her spouse has a relationship property interest in that wealth, the aggrieved spouse is able to attack the transfer and recover his or her share of that wealth.  That is not a new development either.

Note though in these instances it's not so much the trust that's being busted, but the transfer of the wealth.   This is why we say the expression "trust-busting" is something of a misnomer.

Instances like this are grabbing the attention of the press at present (mostly in relationship property claim circumstances) not because the transfer of wealth to a trust is suddenly wrong or illegitimate, and not because trusts are being "busted"; rather the media considers reports of "trust-busting" legal proceedings will catch the attention of the casual reader. 

Here's a further heads-up on that topic.  Once the Government abolishes gift duty we expect it will become more common for creditors to chase wealth thereby moved into the trusts concerned, if New Zealanders start gifting-off large trust debts willy-nilly (that is, without regard to the impact of that gift upon their personal solvency). 

We can advise you if you wish about the ramifications of effecting large scale duty free gifts, before you do so, if gift duty is abolished. 

In the meantime, for those of us who have family trusts, they continue to remain an important part of our asset planning.

If you would like to speak with us about this or any other aspect of your estate planning, please do so.

 

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Consumer Law Reform - slow and steady wins the race

3rd June 2011

 After extensive consultation by the Ministry of Consumer Affairs throughout 2010, a Consumer Law Reform Bill has recently been introduced into Parliament.  The Government intends to pass the Bill into law before the election. 

The Bill aims to revise, update and consolidate New Zealand's consumer laws.  Core consumer law statutes such as the Fair Trading Act 1986 and the Consumer Guarantees 1993 will survive intact (subject to the changes noted below), but lesser known statutes such as the Door to Door Sales Act 1967, Layby Sales Act 1971 and Unsolicited Goods and Services Act 1975 are to be repealed, with their provisions modified and transferred into the Fair Trading Act. 

Apart from this consolidation and the changes noted below, the underlying principles behind New Zealand's consumer laws have been retained.  Despite the detailed commentary from Ministry officials on the need for harmonisation with Australian consumer laws, the introduction of changes such as unfair contract term laws (i.e. minimum requirements for standard form consumer law contracts) have been parked by the Government pending further review in 2014.  The Government has adopted an 'it ain't broke, don't fix it' approach, noting that the existing consumer laws already provide significant protections for consumers.  We agree. 

The most notable changes for businesses are the proposed amendments to the Fair Trading Act.  These amendments include: 

  • The introduction of mandatory disclosure requirements for the sale of extended warranties.
  • New prohibitions on making unsubstantiated representations. 
  • New product safety and product recall provisions. 
  • Extension of the jurisdiction of the Disputes Tribunal to hear some claims for breaches of the Fair Trading Act. 

The other important change for businesses is the introduction of provisions that allow businesses to contract out of the Fair Trading Act in business-to-business agreements, subject to certain requirements of fairness and reasonableness.  This change has come from left-field and was not mentioned in any discussion papers issued by the Ministry of Consumer Affairs. 

Sophisticated commercial entities will often seek to limit their liability for pre-contractual representations by including 'entire agreement' clauses in their contracts.  These clauses seek to limit the liability of the parties solely to those representations (often in the form of warranties) set out in the contract.  The courts have generally upheld the validity of these clauses except in cases of fraud. 

However, the courts have in many cases also had to deal with (and reconcile) 'extra contract' claims brought by an aggrieved company alleging that representations made by another company prior to entry into a business-to-business agreement amount to misleading and deceptive conduct in breach of the consumer-focused provisions of the Fair Trading Act.  This has created anomalous situations where a contractual claim for misrepresentation has been denied (as there has been no fraud) but a claim for misleading and deceptive conduct has been upheld (as parties cannot expressly contract out of the Fair Trading Act).  The changes will bring greater certainty to this issue and limit the circumstances in which claims for breaches of the Fair Trading Act arising from business-to-business contracts will be justified. 

If you require any further information on these amendments or any other aspects of the Consumer Law Reform Bill, please contact Alfred Harford, David Moorman or Patrick Casey. 

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Look-Through Companies and the Demise of LAQCs

10th March 2011

The days of a LAQC will soon be at an end.  Law changes mean LAQC's will no longer be able to attribute losses to shareholders.

A new entity, called a Look-Through Company ("LTC"), will become a reality as from 1 April 2011 and may become the structure of choice for many of the companies currently operating under the Qualifying Company ("QC") rules.  An LTC is a transparent entity for tax purposes in that income and expenditure will be taxed to the LTC owner at their marginal tax rate.  The LTC owner will be able to offset tax losses to the extent the losses reflect the owner's economic loss (i.e. money at risk).  This will be a stricter regime when compared to LAQCs.

Your Options if you have an existing QC or LAQC

You have several options to choose from 1 April 2011.  For instance, you can, without a tax cost:

• do nothing and continue as a qualifying company (QC) without the ability to attribute losses (the default option); or

• be taxed as an ordinary company by revoking your LAQC election, or

• elect to become a LTC; or

• use the new transition rules to become a limited partnership, an ordinary partnership or a sole trader.  You will need to restructure your business and either make the company non-active or wind it up if you choose this option.

Key Criteria

In order to be a LTC, a company must meet the following criteria:

• The company must be a New Zealand tax-resident (under both the NZ income tax legislation also any relevant Double Taxation Agreement)

• There must be 5 or fewer "look-through counted owners" (the ownership interests of relatives are combined)

• The company must have one class of shares, with all shares having the same rights

• The shareholders must be either individuals, trustees, or other LTCs

• The company must meet the eligibility criteria for the whole of the income year.

 Limitation of Losses

Losses of the LTC owner are limited to the investment/money that the LTC owner has at risk.  Any loss that cannot be used is carried forward and may be claimed in future years, subject to the loss limitation rules and/or special rules that apply if the LTC owner sells their shares or if the LTC ceases to be an LTC.  The "at risk" component includes security given by a LTC owner over debts incurred by the LTC (e.g. a personal guarantee of a bank debt incurred to buy a rental property).

Before LAQC shareholders elect into the LTC regime, they will need to carefully review how any losses are funded to ensure they are entitled to claim the LTC's losses.  Failure to plan could result in the ring-fencing of losses against future profits.

In many respects the loss limitation rules for LTCs are similar to those for limited partnerships ("LPs"), although extend slightly further.  Importantly, the LTC entity retains its limited liability status and corporate obligations under company law, and LTC shareholders will be able to take an active role in managing a LTC while retaining limited liability.

Key Decisions

A transitional period will apply that will allow time for decision making, but some key decisions do need to be made.  Factors to consider include:

• If operating through a loss-making LAQC, whether access to those losses is still required.

• If an existing QC/LAQC will transition to a normal company, a LTC, a partnership or become a sole trader, consideration should be given to who should be the QC/LAQC shareholder(s) to achieve the desired transition result.

• If an existing profitable QC has substantial tax-paid retained earnings, then consideration should be given to whether there is a benefit in transitioning on a no tax cost basis to a LTC - there will then be no further layer of tax on entry into the LTC regime, or on the subsequent payment of those earnings to a LTC owner.

• How much money at-risk does a shareholder in a QC/LAQC transitioning to a LTC have, and will it allow all losses to be used by the new LTC owner?

• Does an existing QC/LAQC have or expect to have any realised capital gains that it wishes to distribute without liquidating the company?  Also, is any associated person capital gain expected?

• Will the QC/LAQC be better to opt out of the QC rules and become a normal company for tax purposes - resulting, among other things, in profits being taxed at the 28 percent company tax rate as from 1 April 2011?

If you're a shareholder in a QC or LAQC, we recommend that you seek advice as soon as possible from a tax specialist as to the best tax structure that will suit your business going forward.

The foregoing is intended only as a summary of the new regime, and different factors will apply in individual cases, for which specific advice should be sought.

 

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Proposed consumer law reform - unfair contracts

19th January 2011

The Ministry of Consumer Affairs (Ministry) has concluded an extensive review of consumer laws in New Zealand.  This has been a priority of the Ministry for some time.

The review was based on an earlier wide-ranging discussion paper of the Ministry's that focused on the possible simplification and consolidation of existing consumer laws (including the Fair Trading Act 1986) intended to achieve harmonisation with Australian consumer law.

Despite the "if it ain't broke, don't fix it" response from many business groups (and lawyers) to the Ministry's discussion paper, the Ministry appears fixed upon reform.  The latest indications are that a decision on the final nature of the reform will be made very shortly, with legislation to be introduced early this year.

Unfair Contract Terms

One of the Ministry's initiatives in this reform is to introduce into current Fair Trading legislation, the concept of unfair contractual terms.

Regulation of unfair contract terms has been in place for some time in the United Kingdom, and also forms a key part of the Australian Consumer Law.  The typical nature of unfair contract terms regulation is as follows:

  1. A term of a contract will be void if the term is unfair and the contract is a standard form contract.
  2. A term is unfair if it causes a significant imbalance in the party's rights and obligations and if it would cause detriment to a party if relied upon.  Examples include a clause that allows one party (but not the other party) to terminate the contract or unilaterally vary the terms of the contract, and certain limitations or exclusions of liability.
  3. Any business which contracts on standard terms and conditions of trade will be affected by this type of reform.  While the Ministry has primarily focused on the rights of consumers to challenge unfair contract terms, it has also raised the possibility that this right could apply to small businesses.  The Ministry is undertaking further consultation on this issue, but any extension of this nature would have significant implications for 'big business' in New Zealand.

Be Prepared

The present Government has shown a willingness to act very quickly in passing legislation.  The fact that the Ministry has already undertaken extensive consultation and prioritised this work means an abbreviated select committee process may also apply in this instance.  For these reasons, businesses should:

  1. be prepared for the likelihood of a revised Fair Trading Act in 2011 that includes prohibitions on unfair contract terms;
  2. identify the manner in which they currently contract with consumers and other businesses and the relevant standard form contracts that may be affected by these reforms; and
  3. be ready to react and implement necessary changes to standard form contracts and internal compliance policies, and take legal advice as part of this process.

Malloy Goodwin Harford will continue to closely monitor developments in this area and update clients as the reforms unfold. 

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Fall Out from Earn Out

12th October 2010

A recent decision of the High Court in I-Health Limited v iSoft NZ Limited has highlighted the care that is required in the drafting of earn out provisions and related liability limitations under sale and purchase agreements.

Background

I-Health and iSoft are both health information technology companies.  In December 2003, I-Health and iSoft entered into a sale and purchase agreement under which iSoft agreed to purchase the business and assets of I-Health.  The purchase price was to be not less than $1,475,000 and was subject to an earn out arrangement linked to software revenue made by the iSoft group from the sale of I-Health products over a subsequent five year period. During this period, iSoft was required to use all reasonable endeavours to promote, market and distribute the I-Health products.  iSoft was also obliged to market the software products at a market price.

Ultimately, iSoft did not achieve the anticipated revenue, and only paid I-Health the base purchase price of $1,475,000.  I-Health issued legal proceedings and alleged a breach by iSoft of the 'best endeavours' clauses under the agreement and claimed $14.5 million in damages.  However, the parties sought the determination of a preliminary issue before trial as to the validity of a limitation of liability provision under the agreement. 

Limits on Liability

In a variation to the sale and purchase agreement negotiated shortly before settlement, the parties agreed a monetary cap on iSoft's total liability under the agreement.  The relevant section of the limitation clause read as follows:

 "The maximum aggregate liability of the Purchaser and/or Group (including legal costs and expenses incurred in defending a claim from a third party) under or in relation to this Agreement (including without limitation for negligence and other torts) is limited to $5,000,000.  This limitation of liability does not apply to the Purchaser's liability to pay the Purchase Price or to make payments due to the Vendor for Software Revenue received by the Group." (emphasis added)

The second sentence of the limitation clause (i.e. the exception to the liability cap) was the sentence in dispute.  The critical issue before the Court was whether or not the $5,000,000 limitation on liability applied to the claim for breach of the 'best endeavours' clauses. 

The Court held that while the 'best endeavours' clauses were included under a heading in the agreement marked 'Payment', they had nothing directly to do with the act of payment of the purchase price.  The purpose of the clauses was to impose a positive contractual duty on iSoft to promote and market the I-Health products (and therefore to maximise the purchase price), not to make payment of the purchase price.  The Court held that iSoft's liability to pay involved a different concept from iSoft's liability for breach of an obligation to use 'best endeavours' and therefore this meant the limitation on iSoft's liability applied to any breach of the 'best endeavours' clauses. 

In coming to its decision, the Court was mindful not only of the 'ordinary meaning' of the words used in the limitation of liability provision but also the communications between the parties in the lead up to agreement on the provision.  Consistent with the recent Supreme Court decision in Vector Gas v Bay of Plenty Energy, the Court held that evidence of prior negotiations can be admissible if it sheds an objective light on the meaning of a contractual provision.  Of particular relevance in this case were communications from iSoft during negotiations that made I-Health aware of a previous transaction in which iSoft had been in dispute over a 'best endeavours' clause.  iSoft gave this as its principal reason for requiring the limitation of liability clause.  The Court held that the concern to limit liability was therefore known to both I-Health and iSoft and the various drafts of the relevant clause in the lead up to execution of the Agreement reflected this purpose.  In the Court's view, an objective reading of the communications would lead an objective observer to say "but of course, the limitation clause is intended to limit iSoft's liability for breach of the best endeavours clauses". 

Lessons from the case

There are a number of important lessons from this case.  In particular: 

  • Earn outs are a common way for sellers and buyers of businesses to reach a compromise on the price to be paid for a business.  This is especially relevant in a tough economic environment.  However, they are often complex and contentious, especially where the seller will not retain the ability to influence the performance of the business (e.g. through a management position following settlement).  One suspects I-Health's inability to directly influence the iSoft business may have been at the heart of the dispute in this case. 
  • Care must also be taken to ensure earn out clauses are not simply used as a 'fudge' to get the deal done.  Earn out clauses need to be tailored to each transaction.  This requires legal and accounting advisers and the parties to work together to consider how the earn out mechanism should operate and to reflect this in the sale and purchase agreement.  It is beyond the scope of this article to consider all the risks and pitfalls in earn out clauses.  However, combining clear and measurable goals with clear and unambiguous drafting will go a long way to mitigating many of the risks and pitfalls. 
  • Best endeavours' clauses are also common but often flawed.  The more contentious the issue in negotiations, the more flawed they often become, and they should not be used as the sole parameter for measuring performance.   There is no substitute for clear, objective obligations that seek to avoid the inevitable dispute that will follow the use of 'best endeavours' clauses. 
  • The courts will increasingly look beyond the contract to prior negotiations if there is any uncertainty in the objective meaning of a disputed provision, such as a limitation of liability clause.  Time spent in justifying a position in negotiations (including through e-mail correspondence) may be beneficial if the provision is ever litigated. 

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Fair Trading Act claim leads to a sticky end

16th August 2010

The recent decision of the High Court in WaikatoLink Limited v Comvita New Zealand Limited has reinforced the power of the Fair Trading Act 1986 in contractual disputes.  The case contains some valuable lessons about the care that must be taken when making representations before entering into contracts. 

Background

The case concerned progress towards discovery of a compound or molecule found in manuka honey known as Unique Manuka factor (UMF).  The compound has a unique antibacterial activity that is potentially applicable to various medicinal and cosmetic products. 

The UMF molecule's relevance in the case was through an intellectual property (IP) agreement entered into between Comvita (which creates and sells honey-based healthcare products) and WaikatoLink (the commercialisation and technology transfer company for the University of Waikato).  Comvita alleged that before entering into the agreement, WaikatoLink falsely represented that it had made a discovery placing it on the brink of discovering the UMF molecule, and that Comvita acted in reliance upon this representation.  This amounted to a contractual misrepresentation that induced Comvita to enter into the IP agreement.  Comvita also alleged that this amounted to misleading and deceptive conduct in breach of the Fair Trading Act.    

A sticky start

In December 2005, the parties agreed to commence negotiations to formalise a joint venture between them.  Negotiations around the possible joint venture continued for a number of months, with exchanges of information between the parties. 

However, in early July 2006, the University's lead professor formed the view that he may have identified the UMF molecule and communicated this 'brilliant news' to relevant WaikatoLink staff.  A flurry of activity followed that culminated in WaikatoLink ceasing its joint venture negotiations with Comvita and re-commencing negotiations for an IP agreement on different terms, including increased licence fees.  Despite an initially unfavourable reaction by Comvita to WaikatoLink's change of tack, negotiations continued and the parties entered into the IP agreement. 

The Court heard detailed evidence from the parties as to the communications between them around the time of WaikatoLink's decision to cease joint venture discussions. 

The Court held that WaikatoLink's representations as to the nature of the professor's breakthrough and the increased value of the IP were false, misleading and deceptive.  The professor's July 2006 discovery and communication of 'brilliant news' was in fact a false alarm, something which the professor recognised himself within a fortnight.  The professor communicated his second thoughts to relevant WaikatoLink staff but his messages were lost in translation within WaikatoLink and then in transmission to Comvita.  WaikatoLink continued to represent the original position that the professor was on the brink of a breakthrough.  This inevitably also meant that the representation as to increased value of the IP was wrong. 

The return to the beehive

The IP agreement recorded an acknowledgement that the parties did not rely on any representation, agreement, term or condition that was not set out in the IP agreement (entire agreement clause).  While the Court accepted it was fair and reasonable that the entire agreement clause should be conclusive between the parties for the claim of contractual misrepresentation, the Fair Trading Act claim was less clear cut. 

The Court held that while Comvita did exercise its own judgment when deciding to enter into the IP agreement, it was not satisfied that this factor superseded or overrode the cumulative effect of WaikatoLink's assurances to Comvita.  In order to achieve justice between two sophisticated commercial entities, however, the Court held that Comvita should bear 50% of its own loss, reducing its liability for licence fees owed to WaikatoLink to $1m. 

Key Lessons

This case continues the Courts' attempts to reconcile the application of the Fair Trading Act as consumer legislation to commercial transactions entered into between sophisticated entities.  There are some valuable lessons for contracting parties:

  • Each case will ultimately fall on its own (often complex) facts. 
  • Care must always be taken in making any representations that are not fully grounded in fact before entering into a transaction.  If circumstances change, so must any representation.  This will not always be an easy task in the midst of contractual negotiations and particular care will be required. 
  • Entire agreement clauses can be very useful in dealing with claims of misrepresentation.  However, there is no guarantee that an entire agreement clause will negate a Fair Trading Act claim. 
  • The Fair Trading Act will continue to be a powerful tool in contractual disputes.  However, the Courts will typically seek to achieve an overall balance between sophisticated commercial entities, whether in apportioning liability or fixing compensation. 

The case also brings into question the need for any 'principle based' reform to the Fair Trading Act as recently tabled by the Ministry of Consumer Affairs (see http://www.consumeraffairs.govt.nz/legislation-policy/policy-reports-and-papers/disscussion-papers/consumer-law-reform-a-discussion-paper).  The Ministry's discussion paper is wide ranging and outlines a possible shift to principle-based law, including the addition of a purpose statement to the Fair Trading Act that refers to consumers and suppliers acting in good faith. 

The Ministry fails to present a compelling case for why change is required.  The clear risk is that introducing vague concepts of good faith would introduce further uncertainty, and make the FTA even more pervasive in contractual disputes.  Given the considered approach of the Courts to FTA claims, one can only hope that the Ministry will leave this area of law to evolve on a case-by-case basis without further complication. 


 

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Termination of Franchise Agreements

7th May 2010

Franchising is one of the most popular ways to do business in New Zealand.  Generally, things go well for both the franchisor and the franchisee:  the franchisor receives the benefit of ongoing fees from the franchisee and the franchisee receives the benefit of the hard work done by the franchisor in developing a business concept and building up goodwill in the brand.

Often, however, things do not go quite so well, and this can be a particular problem for a franchisor where the term of the franchise agreement is long, often up to 10-20 years.  With such long terms, it may not be practical for the franchisor to wait out the term of the agreement if there is a problem with a franchisee.  The question arises for franchisors as to how to terminate successfully in such a situation.

Clearly, the franchise agreement will be the first port of call to determine the franchisor's rights and remedies.  A well drafted agreement should contain certain clauses for the franchisor to be able to terminate readily, including if:

  • the franchisee fails to pay any money to the franchisor (eg franchise fees or contributions to an advertising fund);
  • the franchisee fails to reach and maintain minimum standards;
  • the franchisee attempts to assign its interest in the franchise agreement without the franchisor's consent;
  • the franchisee is convicted of any criminal offence;
  • the franchisee becomes mentally incapacitated;
  • the franchisee breaches any of the terms of the franchise agreement (where the breach is not remedied within a specified remedy period);
  • the franchisee damages the franchisor's brand;
  • a receiver is appointed to the franchisee company.

Whatever the cause of termination, it is important that the franchise agreement clearly provides for the franchisor to retain control of the business in the event the franchise agreement comes to an end.  This can be achieved by:

  • ensuring the return of all documents supplied (eg manuals and client lists or any material bearing the franchisor's trade marks);
  • requiring that the franchisee stop trading using the business systems and the franchise name;
  • providing for the franchisor to have control of telephone numbers and other contact details so that clients can directly contact the franchisor;
  • restricting the franchisee from engaging in any competitive activity for a period of time after termination (ie a restraint of trade);
  • permitting the franchisor to take back stock - the franchise agreement should set out a mechanism for determining the price that should be paid for such stock.

Depending upon the nature of lease arrangements for the outlets from which the franchisee carries on business, the franchise agreement should also entitle the franchisor to take up a lease of relevant premises, or cancel any sublease to the franchisee.

A franchisee can also find itself in a position where it wishes to terminate a franchise agreement.  Many franchise agreements will not have specific provisions providing for termination by the franchisee and the franchisee's only remedy where the franchisor is in breach of the franchise agreement is to terminate pursuant to the Contractual Remedies Act 1979.  Often the franchisor will not negotiate on the terms of the franchise agreement but if the franchisee does have some ability to negotiate, then clauses can be included to allow the franchisee to terminate where:

  • the franchisor has breached the franchise agreement by failing to carry out its obligations as franchisor and fails to remedy that breach within a specific period of time;
  • the franchisor is placed in liquidation or receivership.

The franchisee should also consider the consequences of termination.  Will the franchisee be entitled to a refund or rebate of any franchise fee payable?  Will the franchisee be permitted to operate a similar business post termination notwithstanding a restraint of trade in the franchise agreement?  Will the franchisee be able to sell stock and other assets on hand to recoup some of its investment?  

If the franchisor has been placed in liquidation, a franchisee's ability to recover any refund or rebate may be limited.   Any restraint of trade contained within the franchise agreement should arguably not apply where the franchisee has terminated the franchise agreement for cause.  Likewise, a franchisee should have freedom on termination to sell stock and other assets to generate funds to cover bank and other debt.

While a franchisor and franchisee should be committing to a franchise arrangement with confidence that it will succeed, it is important that careful thought be given to the consequences of any necessary termination.  For those involved in franchising, the question should be asked - how good is your franchise agreement and does it contain the clauses you need?

Naturally, the same applies to similar types of commercial arrangement (eg a supply, distribution or licence agreement) and similar issues should be considered.

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Confidential Information

14th April 2010

Every business thrives by keeping a variety of types of information secret: manufacturing processes, marketing strategies, contact lists and employee remuneration packages, to name a few. Collecting or generating information takes time, effort and money. The value of this investment can be significantly affected by deliberate or unexpected disclosure. This can happen, for example, when:

  • A company you have been negotiating with tries to use your information to compete with you;
  • A former employee divulges information to a new employer or attempts to use it for his own gain; or
  • Your information is in the hands of a government department and becomes subject to an official information request.

In each of these circumstances, a court's view on the protection of your confidential information depends to a significant degree on the way you treat the information yourself.

Treatment of Confidential Information

To obtain an injunction preventing disclosure or to obtain an award for damages to compensate for the loss caused by improper disclosure of confidential information, it is crucial to be able to show that the information concerned has been consistently treated as confidential. In some cases, plaintiffs have been surprised to find that information they thought was obviously confidential, such as details of employee remuneration, could not be protected because they themselves had shared that information with a number of people.

To ensure that your valuable information stays secret, it assists to have appropriate contractual arrangements in place that require the maintenance of confidentiality and prohibit unauthorised disclosure. Where that involves entering into non-disclosure agreements or putting confidentiality clauses into a contract, it is important for you to consider with care the clauses that are appropriate in the particular circumstances. It also assists to have effective day to day information handling practices and to limit access to information of a confidential nature.

Fatal Mistakes

Marking a document 'confidential' does not make it so, but failing to mark it 'confidential' can be fatal. Why should a judge grant an injunction or damages to protect information belonging to someone who did not even go to the trouble of marking the documents? Of course, this does not mean that every piece of paper in the office should have a confidential stamp on it!

Overuse of this technique could undermine its value. What is necessary is a careful review of what information needs protection and then putting consistent practices in place for marking documents, keeping them in 'confidential' envelopes and circulating them only to those who need to see them.

Maintain Physical and Electronic Security

The following steps are helpful in maintaining security of confidential information:

  • Make sure employees use passwords to gain access to electronic systems, update their passwords regularly and prohibit employees from sharing their passwords.
  • Shred documents rather than leaving them in a bin where third parties could find them. Keep confidential documents locked in cabinets.
  • Ensure that computers can be locked and implement a policy that requires employees lock computers upon leaving their workstations.
  • Only transport confidential information that is appropriately marked and sealed.
  • Do not leave confidential information in a part of your office or workplace where customers or members of the public might walk past.
  • Monitor employee communications, but remind employees that their email communications will be subject to employer scrutiny. Wide scale dissemination of confidential information can be achieved intentionally or unintentionally at the click of a button.
  • If circumstances arise where it appears that information is going to be disclosed, remind others of their obligations.

Conclusion

The need to treat information as confidential continues throughout the process of generating, gathering, using and storing information. At the outset, get advice about whether to obtain relevant legal protections (eg to seek a patent), have appropriate contracts signed, store executed contracts carefully, and update them when circumstances change. In the course of using information, make sure it is marked and stored with care. Lastly, when you think others might use or disclose the information, remind them of their obligations.

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Imputation Credits and the importance of the 31 March 2010 deadline

1st March 2010

The lowering of the corporate tax rate from 33% to 30% affected the ratio at which a company can attach imputation credits to dividends from 1 April 2008.

A company receives imputation credits equal to the amount of tax it pays.  Prior to the change in the corporate tax rate, a company was entitled to attach these imputation credits to the dividends it declared at a ratio of 33:67 (ie a company could attach $33 worth of credits to each $67 of dividends paid) and as a result the shareholders received a credit on the income tax on the dividends received.  As a result of the change in the corporate tax rate, the ratio changed from 1 April 2008 to 30:70.

Imputation credits are often distributed in a different tax year from when the relevant tax was paid and to implement the change of ratio immediately would have disadvantaged some shareholders where a company still held credits relating to tax paid at 33%.  The Government therefore introduced a transitional period from 1 April 2008 to 31 March 2010 to allow companies to attach imputation credits at the old 33:67 ratio, but only to the extent that the company had imputation credits resulting from tax paid prior to the change in the corporate tax rate (ie: the imputation credits were earned on tax paid at the 33% rate).

The last date a company can distribute dividends imputed at the 33:67 rate is 31 March 2010.

If your company still holds any imputation credits earned prior to the increase in the corporate tax rate then you should consider declaring a dividend prior to 31 March 2010 to ensure the shareholders receive the benefit of a full tax credit of 33 cents for every dollar of gross dividend.  After 31 March 2010, the shareholders will only be able to enjoy a tax credit of 30 cents for every dollar of gross dividend even if the company has paid tax on the income at 33%.

The decision whether or not to declare a dividend may be influenced by the nature of the company's shareholders and the extent to which personal tax rates may change in the May Budget.  If the majority of shareholders are individuals and are on the 38% marginal tax rate, there may be some benefit in deferring declaration of the dividend if personal tax rates are seen as likely to drop below 35% as a result of the Budget.

If you require assistance in declaring a dividend or require any further information, please contact us or your accountant.

 

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Wills Act

2nd February 2010

A new Wills Act was passed in 2007.  It replaced the Wills Act 1837 of the U.K. Parliament.  It applies to persons who die after 1 November 2007 even if their will was made earlier, subject to certain exceptions and qualifications set out in the Act.  No substantial changes have been made to the law but the previous very strict regime has been relaxed somewhat.  Persons over 18 years of age can make wills; younger persons can make valid wills in a variety of circumstances.

If you marry or enter into a civil union, then in most circumstances your will needs to be remade.

If your marriage or civil union is dissolved or certain Court Orders are made between spouses/partners, then your will remains in force but in most circumstances it will be read and administered as if your former spouse/partner had not been mentioned.  All wills should be reviewed regularly and upon any major change in the will-maker's personal or financial circumstances.

If the will-maker has a family trust, it is important for the will and family trust to be integrated.  Settling a family trust and naming it as the beneficiary of your will instead of naming the family members as beneficiaries can confer many benefits upon those family members. 

It is timely to remind everyone that it is desirable to have a will, otherwise your estate is distributed according to the scheme of division set out in the Administration Act which might not be what is wanted. 

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