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Issue 2, 6 April 2011
The Government has introduced a Supplementary Order Paper ("SOP") to the Taxation (Tax Administration and Remedial Matters) Bill to remove tax disadvantages to non-resident investment in PIEs. The SOP is available at www.taxpolicy.ird.govt.nz.
Currently, non-resident investors in PIEs are taxed at 28% on their PIE income.
This results in over-taxation for such investors on the PIE’s foreign assets (a 0% New Zealand tax rate should apply) as well as NZ investments (New Zealand dividends and New Zealand sourced interest are generally taxed at 15% and 10%, respectively, with the latter reduced to 2% under the Approved Issuer Levy, for direct investment).
The Foreign Investment PIE proposal, which is optional, aims to replicate this treatment for non-residents.
Please refer to the article for the key features.
If you have any questions on the above, please speak to your usual KPMG advisor or contact:
Partner - TaxAucklandPhone: +64 9 367 5991
Partner - Tax
WellingtonPhone: +64 4 816 4518
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