What Is a New Zealand Foreign Trust?

Recognition

- The recognition of a trustee company as the "beneficial owner" of income by the "source" state, and

- The applicability of the Double Tax Treaty to the withholding of tax in that other state payable to an New Zealand trustee company

are matters of the application of treaty law in the source state and not matters of the law of New Zealand.

NEW ZEALAND NON-RESIDENT WITHHOLDING TAX (NRWT) RATES AND COUNTRY CODES

Country of Origin	Interest	or	Interest paid to "associated persons"	Dividends	Royalties
Australia	10%^†		10%max	15%^†	10%max
Belgium	10%^†		10%max	15%^†	10%max
Canada	15%^†		15%max	15%^†	15%max
China	10%^†		10%max	15%^†	10%max
Denmark	10%^†		10%max	15%^†	10%max
Fiji	10%^†		15%min	15%^†	15%max
Finland	10%^†		10%max	15%^†	10%max
France	10%^†		10%max	15%^†	10%max
Germany	10%^†		10%max	15%^†	10%max
India	10%^†		10%max	15%^†	10%max
Indonesia	10%^†		10%max	15%^†	15%max
Ireland	10%^†		10%max	15%^†	10%max
Italy	10%^†		10%max	15%^†	10%max
Japan	15%^†		15%min	15%^†	15%min
Korea, Republic of	10%^†		10%max	15%^†	10%max
Malaysia	15%^†		15%min	15%^†	15%max
Netherlands	10%^†		10%max	15%^†	10%max
Norway	10%^†		10%max	15%^†	10%max
Philippines	15%^†		15%max	15% (companies), 25% (others)	15%max
Singapore	15%^†		15%min	15%^†	15%max
Sweden	10%^†		10%max	15%^†	10%max
Switzerland	10%^†		10%max	15%^†	10%max
Taiwan	10%^†		10%max	15%^†	10%max
Thailand	10%^†		10%max	15%^†	15%max
United Kingdom	10%^†		10%max	15%^†	10%max
United States	10%^†		10%max	15%^†	10%max
NZ-South Africa New Treaty not yet in force
^{^†This means the percentage is the final liability. As long as the income has the correct NRWT deducted at source, and it is the recipient’s only income received from New Zealand, he or she does not need to file a New Zealand tax return.}
min This means the rate shown is a minimum rate of tax. the net income (after deducting expenses) must be included in the non-resident’s tax return, along with all other income from New Zealand. Credit is allowed for the NRWT deducted.
max The tax on the income cannot exceed the rate shown.
⁺ This reduces to 15% if fully imputed, fully DWP credited or fully conduit tax-relief credited.