A Change in Direction for New Zealand’s International Tax Regime: Recent Legal Developments

Of all the OECD nations, only New Zealand continues to tax offshore active income on an accruals basis. New Zealand’s almost 20 year old CFC regime was seen by many as being uncompetitive internationally and in dire need of revamp. This paper discusses recent legislative developments which have been designed to draw New Zealand more in line with Australia’s tax regime and to follow international tax law trends. Finally, this paper examines some uniquely New Zealand developments, some recent significant transactions, as well as real estate funds and REITs regarding tax issues in New Zealand.