International Tax

Expats and Migrants

Are you moving to, or leaving NZ? Our tax team has significant experience in NZ and international tax issues for individuals moving here, or relocating abroad. There is a lot to organise, but don’t let tax planning be the task that drops off your list. Being proactive with your tax planning before you move can save you thousands of dollars in unnecessary taxes as well as the headache of getting things wrong.

Tax Planning and Cross Border Structuring

A key part of our offering is to ensure our clients have an efficient and effective structure, which is gained from first working alongside them to understand their unique circumstances, goals and aspirations. Our core objectives are to help our clients retain their wealth through effective, quality tax decisions, and to ensure that tax isn’t keeping them awake at night.

Having an appropriate structure which maximises tax advantages (and minimises disadvantages) is key to these objectives, particularly when trading cross border. International structures inherently pose additional risks - as well as opportunities - and the potential for double taxation is a real risk without the right advice. We can assist with reviewing your existing structure to ensure maximum efficiency, or advise on the best way to establish a business or structure an acquisition or sale.

It is important to seek advice from the outset as it is far easier to establish the right structure from day one, rather than unwinding one that is not fit for purpose. This is critical for all businesses, but particularly so for those with international dealings or ownership.


The taxation of trusts can get murky very quickly, especially for people leaving or moving to NZ. The tax rules that apply to trusts in these circumstances are complex. The potential for double taxation or penalty rates of tax (45%) are a very real risk. Seeking advice from the outset is critical and could be key to avoiding a hefty tax bill.

NZ also has a comprehensive foreign trust disclosure regime and failing to comply with the requirements could result in a tax bill on income that would otherwise not be subject to tax in NZ.

Another area we support with is NZ tax residents receiving inheritances, trust distributions or gifts from overseas. Most people consider these to be tax free windfall payments, and in a lot of cases they are. However, if you have received a gift or distribution from an overseas trust or estate, there may be tax consequences. Being proactive may enable us to provide a recommendation to structure such a gift in a tax efficient manner.

A key risk area for new migrants is NZ’s trust regime. There are limited time periods in which a person has to achieve a favourable outcome. Our core objectives are to help our clients retain their wealth through effective, quality tax decisions, and to ensure that tax isn’t keeping them awake at night. Getting in contact early will ensure you have the best opportunity to protect your wealth and minimise any ineffective taxation outcomes.

Transfer Pricing

We provide comprehensive assistance and advice to businesses in meeting their transfer pricing requirements when trading in NZ or offshore. Transfer pricing is increasingly coming under scrutiny by governments around the world and NZ is no exception. Our team can assist you with:

  • Developing appropriate transfer prices and strategies
  • Planning tax efficient structures and supply chains
  • Preparing and maintaining transfer pricing documentation which complies with local tax legislation
  • Negotiating advanced pricing agreements with the IRD
  • Assisting with the resolution of any IRD reviews or disputes

Foreign Investments

NZ has a comprehensive international tax regime; the rules are complex and can result in unanticipated tax liabilities if not managed appropriately. This is a key area where it pays to get the right advice upfront.

We are experienced in advising on the tax treatment of your foreign investments and providing recommendations to ensure that your investment is structured in the most efficient manner. Often, the NZ treatment will differ to how the investment is taxed overseas. 

Examples of where people get caught out are:

  • Foreign bank accounts, term deposits and mortgages
  • Minor or major shareholding investments in private or family companies
  • Foreign superannuation withdrawals
  • Foreign trust distributions or inheritances
  • Traditional investments in managed funds, shares and bonds

Many of these situations will result in NZ tax consequences. Our team is experienced in advising on these issues and providing recommendations to ensure your tax exposure is minimised.