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Title: International Webinar
Subtitle: Changes coming in 2026
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Kia ora everyone and welcome to this webinar.
My name is Helen Mitchell and with me today is Vicki Cronin.
We are Relationship Managers at Inland Revenue.
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Nau mai Haere mai Welcome
Topics:
- Overseas Pension Transfers
- Foreign Investment Fund (FIF) Rules
- GloBE rules (Pillar 2)
- Crypto-Asset Reporting Framework
- Common Reporting Standard
- Tax Treatment of New Zealand Visitors
- Thin Capitalisation for Infrastructure
- Short selling and foreign shares
- Short process rulings
Audio
We’ll be covering key updates for international tax, including new processes for overseas pension transfers, changes to foreign investment fund rules, updates for global business entities, revised tax treatment for visitors to New Zealand, and changes for thin capitalisation, short selling and foreign shares and short process rulings.
Please note: The information in this presentation is current as at 2 March 2026 and may be subject to change.
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Title: Overseas Pension Transfer
Subtitle: Scheme Pays
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Starting 1 April 2026, Inland Revenue will introduce an optional process called ‘Scheme Pays’ for tax on some overseas pension transfers.
Will help UK migrants who transfer their UK superannuation fund to a New Zealand QROPS.
Currently, they often have a significant tax obligation but can’t access the funds to pay that tax.
With ‘Scheme Pays’, the receiving scheme will withhold tax at a flat rate of 28% of the Assessable Withdrawal Amount (AWA).
KiwiSaver providers can choose to offer the ‘scheme pays’ option to customers transferring a non-QROPS or non-UK pension fund.
Customers can still declare the transfer in their tax return and pay tax at their marginal rate. This will be called ‘individual pays.’
These changes give customers more certainty and flexibility when managing overseas pension transfers.
Audio
Starting 1 April 2026, Inland Revenue will introduce an optional process called ‘Scheme Pays’ for tax on some overseas pension transfers.
This is designed to solve a problem faced by UK migrants who transfer their UK superannuation fund to a New Zealand Qualifying Recognised Overseas Pension Scheme, or QROPS.
Under current rules, they often have a significant tax obligation but can’t access the funds to pay that tax. The new scheme pays option will solve that issue.
With ‘Scheme Pays,’ the receiving scheme can pay the tax directly to Inland Revenue from the transferred funds. Tax will be withheld at a flat rate of 28% on the Assessable Withdrawal Amount—the portion of the transfer treated as income.
Once that tax is paid, the customer has no further tax obligation on that amount.
KiwiSaver providers may also choose to offer this scheme pays option to customers transferring a non-QROPS pension fund.
The existing process will remain in place, and customers can still declare their overseas pension transfer in their tax return and pay tax at their marginal rate. That process will now be referred to as ‘individual pays.’
These changes give customers more certainty and flexibility when managing overseas pension transfers.
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Title: Overseas Pension Transfer
Subtitle: Reporting and Registration
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Receiving schemes must register for a new product called Overseas Pension Transfers (OPT).
All transfers must be reported by the receiving scheme to Inland Revenue.
Reporting will follow investment income procedures:
- Frequency: Monthly
- Method: File upload via myIR
If no transfers occur in a month, no report is required.
Assessable Withdrawal Amounts (AWA) will be recorded for each individual.
Audio
Receiving schemes must register for a new product called Overseas Pension Transfers (OPT).
From 1 April 2026, all transfers need to be reported by the receiving scheme to Inland Revenue. The reporting will follow investment income procedures—monthly uploads via myIR.
If no transfers occur in a month, then no report is required.
Assessable Withdrawal Amounts (AWA) will be recorded for each individual.
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Title: Overseas Pension Transfer
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The slide shows a comparison table with three columns titled Feature, Scheme Pays, and Individual Pays.
Row 1 – Feature: Tax Rate
- Scheme Pays: 28% of AWA, deducted from transferred funds
- Individual Pays: Taxed at the individual’s marginal tax rate
Row 2 – Feature: Where Details Are Viewable
- Scheme Pays: Inland Revenue records
- Individual Pays: Inland Revenue records and myIR
Row 3 – Feature: Included in Income Tax Return?
- Scheme Pays: No
- Individual Pays: Yes
Row 4 – Feature: Counts as Income for Social Policy?
- Scheme Pays: No
- Individual Pays: Yes
Row 5 – Feature: Tax Payment Method
- Scheme Pays: Taken from transferred funds
- Individual Pays: Paid by the customer (cannot be withdrawn from transferred amount)
Row 6 – Feature: Additional Notes
- Scheme Pays: Applies only if customer chooses Scheme Pays
- Individual Pays: IR still notified of transfer; included in end-of-year tax assessment
Audio
Let’s compare the two options for taxing overseas pension transfers.
With Scheme Pays, tax is withheld at 28% from the transferred funds, and the details are recorded by Inland Revenue. This amount doesn’t appear in the customer’s tax return and doesn’t count as income for social policy purposes.
On the other hand, Individual Pays means the customer pays tax at their marginal rate, with details shown in both Inland Revenue records and myIR. The transfer is included in the end-of-year tax assessment and counts as income for social policy.
This comparison may help clients choose the option that best suits their circumstances.
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Title: Overseas Pension Transfer
Subtitle: Important Notes
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Transfers which are tax exempt will still be reported if transferred to a participating scheme.
Individuals are responsible for providing correct information to their receiving scheme.
These rules only apply to the transfer of funds from foreign superannuation schemes into New Zealand.
Audio
It’s important to note that even transfers made within four years of becoming a New Zealand tax resident which are exempt from tax, will still need to be reported if transferred to a participating scheme.
Individuals are responsible for providing accurate information to their receiving scheme.
Finally, these rules only apply to transfers from foreign superannuation schemes into New Zealand, so it’s worth checking the details before proceeding not for transferring New Zealand pensions overseas.
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Title: FIF Rule Change
Subtitle: Addition of Revenue Accounting Method (RAM)
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A new FIF calculation method will allow eligible migrants to be taxed on certain interests when income is realised – that is dividends received and gains or losses when investments disposed of.
Will apply from 1 April 2025.
Audio
The next change relates to the foreign investment fund rules - the revenue accounting method (RAM) is a new FIF calculation method which will allow eligible migrants to be taxed on certain interests when income is realised – that is dividends received and gains or losses when investments disposed of. This will apply from 1 April 2025.
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Title: GloBE rules (Pillar 2)
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Who the rules apply to
In March 2024, New Zealand gave legislative effect to the OECD Global Anti Base Erosion (GloBE) rules.
These rules are designed to ensure large multinational enterprise (MNE) groups pay a minimum level of tax in each jurisdiction where they operate.
The rules only apply to MNE groups operating in New Zealand with global annual revenue exceeding €750m in at least 2 of the preceding 4 years.
When the rules apply
The GloBE rules in New Zealand apply to fiscal years beginning on or after 1 January 2025.
An MNE group has 6 months to register after the end of their fiscal year, when that year began after 1 January 2025 (or 6 months after the end of the 1st year when the rules apply).
The ultimate parent entity’s (UPE) fiscal year-end triggers the timing for registration and other Pillar 2 filing requirements.
Audio
In March 2024, New Zealand gave legislative effect to the OECD Global Anti Base Erosion (GloBE) rules, referred to as the ‘applied GloBE rules’ in New Zealand.
These rules are part of the OECD’s Pillar 2 framework and are designed to ensure large multinational enterprises (MNE) pay a minimum level of tax in each jurisdiction where they operate.
The rules only apply to large MNE groups - specifically those operating in New Zealand with annual revenue exceeding €750m in at least 2 of the preceding 4 years.
In terms of timing:
The GloBE rules in New Zealand apply to fiscal years beginning on or after 1 January 2025. An MNE group has 6 months to register after the end of their fiscal year, when that year began after 1 January 2025 (or 6 months after the end of the 1st year when the rules apply).
The ultimate parent entity’s (UPE) fiscal year-end triggers the timing for registration and other Pillar 2 filing requirements.
For example, an MNE with a fiscal year ending:
31 December 2025 must register by 30 June 2026
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Title: GloBE rules (Pillar 2)
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Registration
One designated New Zealand constituent entity must register and complete the notification and reporting on behalf of all New Zealand constituent entities.
If the designated entity changes:
- The existing entity must de register
- The new designated entity must register
Pillar 2 registration will be available in myIR from 16 March 2026.
Once registered, customers will see a GBE account type in myIR
Web messages can be sent under the GBE account.
More information is on our website: ird.govt.nz/pillar-2-registration
Tax agent linking
A tax agent can complete the registration and other GloBE filing requirements where they are not linked to the customer’s other accounts.
The GBE account will be a separate account type in myIR the tax agent can link to.
Audio
Pillar 2 in New Zealand is administered through a single registration for each MNE group with constituent entities in New Zealand.
A designated New Zealand constituent entity will register and complete the notification and reporting on behalf of the other New Zealand constituent entities.
If that designated entity changes, the existing entity will need to de register and the new one must register.
The registration includes the notification requirement under the applied GloBE rules and therefore must be completed by all MNE groups that these rules apply to. This notification includes details of the Ultimate Parent Entity (UPE), where the GloBE Information Return (GIR) is to be filed and other NZ Constituent Entities included in the group.
Pillar 2 registration will be available in myIR from 16 March 2026. Please note: filing options will become available in myIR later in the year. We will provide further updates about this.
Once registered, customers will see the GBE account type in myIR and they will be able to send us web messages under this account.
More information about the Pillar 2 registration and filing requirements can be found on the Inland Revenue website - ird.govt.nz/pillar-2-registration.
Tax agents can complete the registration and other GloBE filing requirements, even where they are not linked to the customer’s other accounts. The GBE account will be a separate account type in myIR that tax agents can link to.
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Title: Crypto-Asset Reporting Framework
Subtitle: Adopting the framework
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New Zealand is adopting the Crypto-Asset Reporting Framework (CARF) developed by the OECD.
This international exchange framework introduces information reporting requirements for Reporting Crypto-Asset Service Providers (RCASPs).
Focuses on crypto-assets, which can be transferred and held outside of banks and other traditional financial intermediaries.
Audio
To increase the visibility of activities in the crypto-asset sector, New Zealand has adopted the Crypto-Asset Reporting Framework (CARF) developed by the OECD.
This international exchange framework introduces information reporting requirements for Reporting Crypto-Asset Service Providers (RCASPs) such as crypto exchanges, trading platform operators and brokers.
The information will focus on crypto-assets, which can be transferred and held outside of banks and other traditional financial intermediaries.
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Title: Crypto-Asset Reporting Framework
Subtitle: Who is an RCASP
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An RCASP is any individual or entity carrying out the exchange or conversion of crypto-assets on behalf of users as a business, including those serving as a counterparty, intermediary or providing a trading platform.
RCASPs do not include individuals or entitles that:
- are wallet providers offering storage only
- create or sell platforms, software or applications, provided they do not use these to facilitate the exchange or conversion of relevant crypto-assets on behalf of their users
- only create and issue relevant crypto-assets
- are an investment fund investing in relevant crypto-assets on behalf of investors
- are only engaged in crypto-asset activities for their own benefit.
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An RCASP is any individual or entity carrying out the exchange or conversion of crypto-assets on behalf of users as a business, including those serving as a counterparty, intermediary or providing a trading platform.
It does not include individuals or entitles that:
- are wallet providers offering storage only
- create or sell platforms, software or applications, provided they do not use these to facilitate the exchange or conversion of relevant crypto-assets on behalf of their users
- only create and issue relevant crypto-assets
- are an investment fund investing in relevant crypto-assets on behalf of investors
- are only engaged in crypto-asset activities for their own benefit.
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Title: Crypto-Asset Reporting Framework
Subtitle: What RCASPs must do
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Starting 1 April 2026, New Zealand-based RCASPs must:
collect from all crypto-asset users identifying information and details about their tax residency
report detailed information about relevant transactions
file reports annually in the prescribed format
keep records for 7 years.
RCASPs must carry out due diligence to determine if a crypto-asset user is a reportable user.
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Starting 1 April 2026, New Zealand-based RCASPs must:
- collect from all crypto-asset users identifying information and details about their tax residency
- report detailed information about relevant transactions
- file reports annually in the prescribed format
- keep records for 7 years
From 1 April 2026 RCASPs must carry out due diligence actions to determine if a crypto-asset user is a reportable user.
To do this, they must get self-certification from all users which includes identifying information and details such as tax residency. This must be signed or otherwise positively affirmed by the user to be valid.
For new users, due diligence must be completed before any transactions are facilitated. For pre-existing users with an account as of 31 March 2026, they must have the self-certification by 31 March 2027.
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Title: Crypto-Asset Reporting Framework
Subtitle: Reporting to us
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The first reporting period covers transactions from 1 April 2026 to 31 March 2027, with the first report due by 30 June 2027.
RCASPs will need to register with us for a Crypto-Asset Reporting Framework (CRF) account.
They will be able to register in myIR when this is available.
Using this account, they will need to file reports by 30 June each year.
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The first reporting period covers transactions from 1 April 2026 to 31 March 2027, with the first report due by 30 June 2027.
RCASPs will need to register with us for a Crypto-Asset Reporting Framework (CRF) account. They will be able to register in myIR when this is available.
Using this account, they will need to file reports by 30 June each year.
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Title: Crypto-Asset Reporting Framework
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Exchange of information between countries
We will share information received from New Zealand-based RCASPs with other tax authorities that use the OECD framework if the information is about users who live in their country.
We will receive information from other tax authorities about income earned by New Zealand tax residents using RCASPs in their jurisdiction.
What we will use the information for.
We will use this information to check that income earned by New Zealand tax residents is included in their income tax returns.
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We will share information received from New Zealand-based RCASPs with other tax authorities that use the OECD framework. This will happen for crypto-asset users who are not New Zealand tax residents – their information will be shared with their tax authority.
We will also receive information from other tax authorities about income earned by New Zealand tax residents using RCASPs in their jurisdiction.
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Title: Crypto-Asset Reporting Framework
Subtitle: OECD Guidance
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Our website has been updated to include information on the framework and links to the OECD guidance.
You can find this at ird.govt.nz/CARF
If you have any questions about CARF you can send these to [email protected]
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Our website has been updated to include information on the framework and links to the OECD guidance. You can find this at ird.govt.nz/CARF
We are developing further guidance to support RCASPs and these publications will be added to our website when they are available.
If you have any questions about CARF you can send these to [email protected]
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Title: Amendments to the Common Reporting Standard
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From 1 April 2026, the Common Reporting Standard (CRS) due diligence and reporting requirements change.
Indirect investments in crypto-assets through derivatives and investment vehicles, specified electronic money products, and central bank digital currencies, are now captured under the CRS.
There are also changes to strengthen the due diligence and reporting requirements.
The changes have no impact on the CRS reporting period ending 31 March 2026.
Audio
There are also amendments for the common reporting standard.
The common reporting standard enables the exchange of financial account information and requires financial institutions to carry out due diligence by reviewing their financial accounts held and/or in circumstances controlled by relevant foreign tax residents.
From 1 April 2026, the common reporting standard due diligence and reporting requirements change.
Indirect investments in crypto-assets through derivatives and investment vehicles, specified electronic money products, and central bank digital currencies, will now be captured under the CRS.
There are also changes to strengthen the due diligence and reporting requirements.
We have updated our guidance incorporating these changes this is available on our website. This guidance is specific for the CRS period ending 31 March 2027 and onwards. The changes have no impact on the CRS reporting period ending 31 March 2026.]
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Title: Tax Treatment of New Zealand Visitors
Subtitle: Residency Status
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Eligible non-resident visitors will be treated as non-residents for tax purposes for up to 275 days within an 18-month period, if they meet all of the following criteria:
- They are a natural person
- They are lawfully present in New Zealand
- They stay in New Zealand for 275 days or fewer in any 18-month period.
- They are not working for or paid by a New Zealand resident or a New Zealand branch of a non-resident employer.
- Their remote work does not require them to be in New Zealand.
- They are not offering goods and services in New Zealand for income from persons or businesses in New Zealand.
- They and their partner do not receive a family scheme entitlement (Working for Families, Best Start).
- They are a tax resident in a country that has a comparable income tax system to New Zealand’s.
- They were not a New Zealand resident or transitional resident immediately before qualifying.
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In January 2025, the New Zealand Government announced that visitor visa holders can work remotely while they’re in the country. Starting from 1 April 2026, new tax rules will come into effect to make compliance easier and provide clarity for international visitors.
Eligible non-resident visitors will be treated as non-residents for tax purposes for up to 275 days within an 18-month period, provided they meet all of the criteria, including:
- The person must be a genuine visitor who is lawfully in New Zealand, staying short-term (under 275 days in 18 months), and not tied to local employment or income.
- Their work is remote and doesn’t require being in New Zealand, they’re not selling goods or services locally, and they don’t receive family entitlements.
- They must also be a tax resident in a country with a comparable tax system and not have been a New Zealand resident immediately before qualifying.
If someone no longer qualifies as a non-resident visitor, standard tax residency rules will apply. Their tax treatment after that will depend on whether they remain in New Zealand lawfully.
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Title: Tax Treatment of New Zealand Visitors
Subtitle: Income Exemptions for Non-Resident Visitors
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Remote work income is exempt from New Zealand income tax if:
- The work is done for a non-resident client or employer, and
- The income is taxable in another country.
Fringe benefits received by employees of non-resident companies are exempt from Fringe Benefit Tax (FBT).
Employer superannuation contributions made by non-resident employers for non-resident visitors are not subject to Employer Superannuation Contribution Tax (ESCT).
These exemptions do not apply to public entertainers.
A non-resident visitor’s presence in New Zealand will not affect a company’s tax residency status.
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Remote work income will be exempt from New Zealand income tax if two conditions are met: the work is done for a non-resident client or employer, and the income is taxable in another country.
In addition, fringe benefits provided to employees of non-resident companies will be exempt from Fringe Benefit Tax.
Employer superannuation contributions made by non-resident employers for non-resident visitors will also not be subject to ESCT.
These exemptions do not apply to public entertainers. And importantly, a non-resident visitor’s presence in New Zealand will not affect a company’s tax residency status.
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Title: Tax Treatment of New Zealand Visitors
Subtitle: GST Registration Threshold
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Non-resident visitors can exclude the value of services provided to non-resident clients when calculating whether they exceed the GST registration threshold, if:
- The services are not related to land or movable personal property in New Zealand.
- The services are provided to someone who is a non-resident and outside New Zealand at the time the services are performed.
Non-resident visitors can still choose to register for GST if they meet the standard criteria, even if they only supply services to non-residents.
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Non-resident visitors can exclude the value of services provided to non-resident clients when calculating whether they exceed the GST registration threshold, provided the services are not related to land or movable property in New Zealand, and the services are supplied to someone who is a non-resident and outside New Zealand at the time the services are performed.
Even with these exclusions, non-resident visitors can still choose to register for GST if they meet the standard criteria—even if they only supply services to non-residents.
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Title: Thin Capitalisation Settings for Infrastructure
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Proposed rule will allow eligible NZ businesses to fully deduct interest on third party, limited recourse debt, even if this exceeds standard thin capitalisation limits.
Eligibility requires the business or project's main activity to be creating, operating, maintaining, or upgrading qualifying NZ infrastructure assets it owns.
The rule will be available to any eligible customer subject to standard thin capitalisation rules.
The debt must be:
- from an unrelated third party unless the business is a listed company and the lender is an investor whose shareholding is 5% or less, and
- limited recourse
Applies from the 2026–27 income year.
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For Thin Capitalisation, a proposed rule will allow eligible New Zealand businesses to fully deduct interest on third party, limited recourse debt, even if this exceeds standard thin capitalisation limits.
Eligibility requires the business or project's main activity to be creating, operating, maintaining, or upgrading qualifying NZ infrastructure assets it owns.
Ancillary or facilitative activities (example, an airport with income from retail spaces or hotels attached to the airport) do not prevent eligibility when they support the core infrastructure purpose.
The rule will be available to any eligible customer subject to standard thin capitalisation rules, and may apply to a single company, a wholly owned group, or a subset of that group. Entities with the right to receive infrastructure and finance levies are also included, recognising Crown approved infrastructure arrangements.
The debt must be from an unrelated third party unless the business is a listed company and the lender is an investor whose shareholding is 5% or less and must be limited recourse, meaning lenders only have recourse to NZ infrastructure assets, income streams, and ownership interests within the eligible investment.
There is no restriction on paying dividends/returning capital, where that is a legitimate commercial activity.
Electing into the rule ring fences the debt, interest, assets, and any acquisition goodwill from the wider group’s thin capitalisation calculation.
This would apply from the 2026–27 income year.
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Title: Short selling and foreign shares
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Generally, foreign shares used in a short selling arrangement will be taxable under ordinary revenue account property rules.
Will apply from 1 April 2025.
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Generally, where foreign shares are used in a short selling arrangement the transaction will be taxable under ordinary revenue account property rules and not the foreign investment fund (FIF) regime.
Applies to returning share transfers entered into on or after 1 April 2026.
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Title: Short process rulings
Subtitle: Non-resident applicants with income over $20 million
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Non-resident applicants will have their foreign sourced income included when determining whether they meet the $20 million eligibility threshold for a short-process ruling.
Income will be measured using the non-resident’s most recently completed financial year.
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Our final change relates to short process rulings.
Non-resident applicants will have their foreign sourced income included when determining whether they meet the $20 million eligibility threshold for a short- process ruling.
Income will be measured using the Non-resident’s most recently completed financial year.
This will ensure short- process rulings remain targeted at Small to Medium Enterprises and ensures that non-resident applicants and resident applicants are treated the same.
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Body text:
Ngā mihi maioha
Audio
That brings us to the end of our webinar.
If you want to find out more about the other webinars available for April Release 2026, go to www.ird.govt.nz/april-release
Thank you for watching.
Last updated:
23 Mar 2026