We have considerable expertise advising on tax residency issues for individuals migrating to or from New Zealand. There are often limited windows to undertake pre-migration tax planning, particularly for returning residents who do not qualify for the transitional residents exemption. We are also experienced in the interpretation and application of New Zealand’s double tax agreements. The articles in a double tax treaty override the domestic laws of the Contracting States therefore it is paramount to consider the relevant tax treaty provisions when providing advice.
We regularly advise New Zealand residents on the taxation of overseas investments which often touch on the more complex areas of the Income Tax Act such the CFC and FIF regimes and the Financial Arrangements rules. New Zealand has robust international tax regimes applying to New Zealand residents with interests in overseas entities such as companies and unit trusts.
We often see overseas entities which are fiscally transparent in an overseas jurisdiction such as LP’s, LLC’s, S-Corps and advise on how these should be treated for New Zealand tax purposes. More often than not, the New Zealand treatment does not mirror the overseas treatment which can lead to complexities and tax inefficiencies.
Structuring cross border business operations to achieve tax efficient outcomes is a major focus of our work. Double taxation issues commonly arise when businesses pay tax in a different jurisdiction to that in which the owners reside. We have access to tax advisers in numerous countries through our association with RSM International to ensure that any issues arising in foreign jurisdictions are adequately addressed. It pays to get the structure right from the outset as getting it wrong can be costly and once established, structures can’t be easily unwound.