Tax Treaties Guide — Double Tax Agreements Between NZ and Other Countries
the Double Tax Agreements (DTAs) between New Zealand and the other countries. The guide covers the 40+ DTAs, the withholding tax rates under the treaties, the permanent establishment rules, the tie-breaker provisions for the dual residents, and how to claim the treaty benefits.
NZ Tax Treaty Network
New Zealand has the comprehensive Double Tax Agreements (DTAs) with the 40+ countries, including the Australia, the United Kingdom, the United States, the Canada, the Japan, the China, the South Korea, the Singapore, the Malaysia, the India, the Indonesia, the Thailand, the Vietnam, the Philippines, the Papua New Guinea, the Fiji, the Cook Islands, the NIue, the Samoa, the Tonga, the Tuvalu, the Kiribati, the Vanuatu, the Solomon Islands, the Nauru, the Marshall Islands, the Palau, the Micronesia, the Chile, the Mexico, the South Africa, the UAE, the Turkey, the Russia, and the European Union countries. The DTAs allocate the taxing rights between the countries and reduce the withholding tax rates.
Key Treaty Provisions
The key treaty provisions include: (a) the withholding tax rates — the dividends (15% for the portfolio, 5% for the substantial holdings), the interest (10% to 15%), and the royalties (5% to 15%), (b) the tie-breaker test — for the individuals who are the dual residents (the "permanent home", the "centre of vital interests", the "habitual abode", the "nationality" as the tie-breakers), (c) the permanent establishment (PE) threshold — the fixed place of business or the dependent agent creating the PE (typically 6 to 12 months for the construction projects), and (d) the exchange of information — the automatic exchange of the financial account information under the CRS (the "Common Reporting Standard").