Jurisdiction — Territorial — Investigation into alleged tax evasion — Company using foreign tax haven — Alleged participation in tax evasion transactions by foreign State — Disclosure of financial information an offence under laws of the tax haven State — Whether individuals residing in forum State can be compelled to give evidence to commission of inquiry where to do so would breach laws of tax haven State — Whether legislation having extraterritorial effect — Whether privilege against self-incrimination applicable in respect of offence under foreign law

State immunity — Jurisdictional immunity — Public policy as ground for refusing claim of immunity — Investigation into alleged tax evasion by use of foreign tax haven — Alleged participation by foreign State in transactions — Alleged use of Cook Islands tax haven by New Zealand companies to evade New Zealand tax liabilities — Transactions involving sale and purchase of promissory notes and issue of tax payment certificates by Cook Islands to be used against New Zealand tax liabilities — Commercial activity exception — Whether activities classed as operation of tax regime or as sale of tax credits — Whether public policy considerations outweigh other criteria in determining whether State immunity applicable — “Inquity factor” — Whether Cook Islands Government Auditor can be compelled to produce documents in his possession in New Zealand to commission of inquiry — The law of New Zealand