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Non-New Zealand Residents and International Trusts

Our specialists are experienced in advising non-New Zealand resident individuals and international trusts on the New Zealand implications of investing in, migrating to or having a presence in New Zealand.


  • Exemption from New Zealand tax for new and some returning residents on most offshore income (for a period of 4 years)
  • Use of pre-migration asset protection trusts for high net worth individuals
  • Application of New Zealand’s Controlled Foreign Company (CFC) and Foreign Investment Fund (FIF) rules to the investment in offshore companies and funds
  • Offshore pensions and annuities
  • Investing in New Zealand while remaining non-resident.

International trusts

  • Exemption from NZ tax for offshore income derived by international trusts.
  • Disclosure requirements for international trusts where a New Zealand resident trustee is appointed.
  • Distributions to New Zealand resident and non-resident beneficiaries.
  • Reviewing, preparing and interpreting trust instruments.

We work regularly with our clients’ offshore advisors to ensure that all cross-border tax and legal considerations are taken into account. This is the case whether an individual is intending to live in New Zealand while retaining significant assets offshore (such as ownership of companies incorporated in the US or elsewhere) or remaining offshore while investing in New Zealand (such as by establishing an agriculture farming operation in New Zealand).

Our expertise extends to advising on the New Zealand tax implications for New Zealand-based recipients of foundations established in various civil law jurisdictions.