Skip to main content

myIR outage

For system maintenance, some myIR services will be unavailable between 10pm Saturday 15 June and 6am Sunday 16 June. Thank you for your patience.

Te hinonga kohinga haumi o tāwāhi Foreign portfolio investment entity


Notified foreign investors (NFI) invest in two types of foreign portfolio investment entities (PIEs). These PIEs let investors have a tax result similar to what would apply if they invested directly in the PIE's assets.

A non-resident who derives non-New Zealand sourced income is not liable for New Zealand income tax on that income.

Foreign PIEs can use 0% PIR for the offshore income they attribute to the NFI.

Once every year foreign PIEs must check their investors are still NFIs.

Foreign zero-rate PIE

Zero-rate PIEs invest most of their funds in non-New Zealand based investments. These PIEs only have a minimal amount of funds in New Zealand.

A zero-rate PIE applies 0% PIR to all income attributed to NFIs.

Foreign variable-rate PIE

Variable-rate PIEs invest their funds in New Zealand and offshore.

There is no New Zealand-based investment threshold for this type of PIE.

These PIEs apply the following rates based on the type and source of income:

  • All offshore income: 0%
  • Income under the financial arrangement rules other than interest: 0%
  • New Zealand interest income: 1.44%
  • New Zealand unimputed dividend income with an investor that is affected by our double tax agreements: 15%
  • New Zealand unimputed dividend income with an investor that is not affected by our double tax agreements: 30%
  • Any other New Zealand based income: 28%

A variable-rate PIE can sometimes treat the unimputed portion of New Zealand dividends as liable for non-resident withholding tax (NRWT). This allows the NFI to claim a tax credit in their country of residence. This income is not treated as PIE income.

Look-through entities

A retail foreign investment PIE that invests into a wholesale PIE can treat the wholesale PIE as a look-through entity. This lets the PIE identify the NFI's:

  • source and type of income
  • expenses.