New Zealand Tax Treaties follow the standard OECD model, with certain specific derogations.

In general, the New Zealand rules differ from that of the OECD model in that the place of effective management of an enterprise is not always where overriding control is exercised, but where practical day-to-day management occurs. This has important consequences for the New Zealand Foreign Trust, as the trustee must not only be a New Zealand resident but must effectively carry out its functions in New Zealand. That is achieved not only by the Trustee being resident in New Zealand, but also by reason of the trust being effectively managed in New Zealand by its resident director.