New Zealand


  • Service: Tax
  • Type: Business and industry issue
  • Date: 6/04/2011


Our tax advisory team has the skills and commitment to help you to be competitive and compliant in all areas of business tax.

Taxmail - Draft legislation on Foreign Investment PIEs released 

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


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:


Paul Dunne

Partner - Tax
Phone: +64 9 367 5991

John Cantin

Partner - Tax

Phone: +64 4 816 4518

Taxmail - Comment on topical tax issues from KPMG NZ Tax. 

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