Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, it can not replace a tax advice, or be considered as an official information.
Yes we tax in New Zealand
New tax reform: No specific information
New tax treaties:
- Tax treaty between New Zealand and Slovak Republic is under negotiation.
- Tax treaty between New Zealand and Saudi Arabia is under negotiation.
Local tax advisors
No specific information on the local tax advisors.
Local tax administration
The definition of Fixed Establishment follows is a fixed place of business in which substantial business is carried on by a person.
Resident companies are taxed on their worldwide income. However, non-resident companies are only taxed on their revenues derived from New Zealand sources.
Entities are considered to be resident for tax purposes in New Zealand if they are incorporated in New Zealand, if their head office is in New Zealand, if their place of management or control is in New Zealand.
Note: the definitions of permanent establishment and place of residence are subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 28%.
Non-deductible expenses includes the following:
- CIT and similar taxes (including foreign withholding taxes);
Carry forward: Yes indefinitely, but some restrictions may apply.
Carry back: No
Companies should submit the tax return annually.
Annual tax returns are established by the company on a self-assessment system.
Whithholding Taxes (payment to foreign companies)
The local tax rates in New Zealand are the following, subject to the provisions of an applicable double tax treaty, if any.
There is no WHT on the profits paid from a branch to its foreign head office.
The general rate of WHT on dividends is 15% of the gross amount.
The general rate of WHT on interest is 15%.
Note: in case where Approved Issuer Levy is paid, WHT is 0%.
The general rate of WHT on Royalties is 15%.
No specific information for WHT on management fees.
No specific information for WHT on technical services.
Capital gains are generally not taxed.
Note: Certain capital gains deriving from real property or from unrealized capital accretions, may be included in in the CIT taxable basis.
Standard GST tax rate is 15%
Zero-rated supplies include, subject to certain conditions:
- Exports of goods;
- Goods not located in the custom territory of New Zealand at the time of the supply;
- Goods related to Aircraft engaged in commercial international traffic;
- Services related to zero-rated vessels and Aircraft;
- Services performed outside the custom territory of New Zealand;
- Certain financial services;
- transport of goods and services directly related to import and export of goods;
- Passenger transportation;
Exempt supplies include, subject to certain conditions:
- Certain financial services (exchange of currency, issue and transfer of debt, equity,…)
- Certain insurance services
Note: exempt transactions differ from zero-rated transactions in that the input GST associated with exempt transactions is not deductible.
In case where for a tax period, Input GST exceeds Output GST, certain non-resident companies (which are not required to register and incur New Zealand-GST in the course of their business activities in Netherlands) may apply for a refund, provided that services are provided to non-resident customers and the products are exclusively exported.
No other specific information of GST in New Zealand.
The general statute of limitation is 7 years starting at the end of the year in which the tax return had to be filed.
The statute of limitation could be extended in certain cases.
There is no foreign exchange control in New Zealand. Income and capital could be freely repatriated.
There are thin capitalization rules in New Zealand. The interest derived from loans between related parties may not be deductible in case where interest exceeds some ratios.
Do not hesitate to share your experience in New Zealand with us in the comments below. Any comments are welcome !