International Trusts and Non-New Zealand Residents

International trusts and individuals living outside New Zealand (whether or not they are thinking of migrating) need to understand the implications of investing in, or having a presence in, New Zealand.

We have a depth of experience with international trusts, working alongside our clients’ offshore advisors to ensure that all cross-border tax and legal considerations are taken into account.

We regularly advise International Trusts on:

  • exemption from New Zealand tax for offshore income
  • tax law disclosure requirements where a New Zealand resident trustee is appointed
  • distributions to New Zealand and non-New Zealand beneficiaries
  • reviewing, preparing and interpreting trust instruments.


We also advise on the New Zealand tax implications for New Zealand-based recipients of foundations established in civil law jurisdictions.


Individuals who are thinking of migrating to New Zealand while retaining valuable assets offshore or who plan to remain offshore while investing in New Zealand, need the tax and legal advice that we can provide.

We regularly advise individuals on:

  • exemption from New Zealand tax for new, and some returning, residents on most offshore income (for an exempt period of at least 48 months)
  • 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) tax rules to the investment in offshore companies and funds
  • New Zealand implications of offshore pensions and annuities
  • investing in New Zealand while remaining outside New Zealand.

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