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Ngā pūtea haumi o tāwāhi Foreign investment funds


A foreign investment fund (FIF) is an offshore investment that is:

  • a foreign company
  • a foreign unit trust
  • a foreign superannuation scheme (prior to 1 April 2014)
  • a FIF superannuation interest
  • an insurer under a foreign life insurance policy.

The shares in these holdings usually need to be under 10% to be classed as a FIF.

Download our Guide to foreign investment funds and the fair dividend rate for details information on FIFs. This guide includes a chart to help determine the tax treatment of offshore financial holdings, and how to account for your foreign income.

Foreign investment fund income

Income attributed from a foreign investment is defined as FIF income. This may mean an investor has FIF income before actually receiving any money.

Calculating FIF income

There are different methods to calculate your foreign investment fund.

Investors with less than NZ$50,000 of attributing interest in a FIF are not required to calculate income under the FIF rules. These investors will continue to pay tax only on dividends received.

Disclosing a foreign investment fund or controlled foreign company

You must disclose your FIF or CFC in your tax return. To do this you will need a few details:

  • the name of the investment
  • the country of incorporation or tax residence
  • the market value in New Zealand dollars at the beginning or end of your income year.

CFCs disclosures will also need:

  • the primary business activity
  • a copy of financial statements
  • the number of employees.

If you are a New Zealand resident with an attributing interest in a FIF, and you calculate FIF income or loss using the cost method, you need to disclose this with an IR449 form.