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Ngā kamupene kainoho tāke o Aotearoa New Zealand tax resident companies


A company is a resident in New Zealand if it:

  • is incorporated in New Zealand
  • has directors with control exercised in New Zealand
  • has centre management or its head office in New Zealand.

Double tax agreements

Between most countries, these state that a company with a permanent establishment in New Zealand will have income tax requirements here.

Permanent establishment guides

A business with a fixed place where business activity is carried on is a permanent establishment. This may include:

  • a branch, office, factory or workshop
  • a resource position, such as a mine, oil well, quarry or water spring
  • an agricultural, pastoral or forestry property
  • a building, construction site or assembly project that lasts more than six months.

Activities may also be considered as a permanent establishment:

  • supervisory activities with a building, site or assembly project
  • exploration responsibilities for resources
  • substantial equipment uses for more than six months
  • any operations around standing timber.

When activities are not considered a permanent establishment

Generally, maintenance activities will not count as a permanent establishment. These could include maintenance of:

  • storage, display or delivery of goods and merchandise
  • goods or merchandise are used for processing by another entity
  • a fixed place of business used for collecting information
  • a fixed place of business used for introductory or supporting nature.