Comparing the New Zealand Foreign Tax Exempt Trust
Update: 2025-09-20
Description
New Zealand’s tax system treats trusts according to the residence of the settlor. Under section CW 54 of the Income Tax Act 2007, resident trustees can access an exemption for foreign-sourced income if they meet the criteria in section HC 26. Following the 2016 Government Inquiry into Foreign Trust Disclosure Rules, New Zealand introduced stricter requirements—formal registration, greater disclosure, and broader access for authorities such as the Department of Internal Affairs and the New Zealand Police. These changes aimed to safeguard New Zealand’s reputation while tightening oversight of foreign trusts.
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