Commissioner of Inland Revenue v JFP Energy Inc - [1990] 3 NZLR 536

Revenue — Income tax — Double taxation relief — United States resident employees of a US company with a permanent establishment in New Zealand worked part-time in NZ but were paid in the US from the company's US funds — Whether the employees were liable for NZ income tax on all or part of their income — Whether employees' income, although paid by the US company, was "borne by" the permanent establishment — Double Taxation Relief (United States of America) Order 1983, articles 7 and 15.