The protocol (i) updates the provision governing exchange of information, and (ii) inserts a new provision to allow assistance with tax collection. These changes will assist the extension of Australia's wine equalization tax rebate to New Zealand wine producers that export to Australia.

Whether or not the two countries will negotiate a completely new tax treaty is still under review. It will depend in part on whether New Zealand is willing to lower the withholding rates covered by the treaty, a decision the New Zealand government expects to make in 2006.

The protocol will be given effect in both countries once they have introduced the necessary domestic legislation, which in New Zealand's case will be an Order in Council, probably in early 2006.