Equities - rates, eligibility, availability of relief etc. - New Zealand

06.09.2023

Withholding Tax

Standard rate of withholding tax:

0% / 15% / 30%

Holding requirements / restrictions:

Yes

The standard rate of Non-Resident Withholding Tax (NRWT) on dividends from New Zealand equities is 30% for beneficial owners who are non-residents of New Zealand.

Under New Zealand tax legislation, several types of tax credit can be attached to a dividend payment, depending on the type of income and, as a consequence, dividends can be distributed as follows:

  • From ordinary equities:
    • Unimputed – subject to the standard rate of 30% withholding tax - certification required from the client to obtain reduced tax rate;
    • Partially Imputed – subject to the standard rate of 30% withholding tax, but only for the unimputed portion of the dividend, the remainder being taxed at 15% - certification required from the client to obtain reduced tax rate;
    • Fully Imputed – subject to 15% withholding tax, regardless of country of residence – no action required by the client to ensure that this reduced rate is applied.
    • Supplementary – subject to 15% withholding tax, regardless of country of residence – no action required by the client to ensure that this reduced rate is applied.
  • From Portfolio Investment Entity (PIE) equities:
    • Unimputed – subject to the standard rate of 0% withholding tax, regardless of country of residence – treated as excluded income;
    • Fully Imputed – subject to 15% withholding tax, regardless of country of residence – no action required by the client to ensure that this reduced rate is applied.
    • Supplementary – subject to 15% withholding tax, regardless of country of residence – no action is required by the client to ensure that this reduced rate is applied.

Availability of relief

Beneficial owners can obtain exemption at source or relief at source from withholding tax on dividend from New Zealand equities as follows:

Eligible beneficial ownersRelief at sourceQuick RefundStandard Refund

Residents of Double Taxation Treaty (DTT) countries

Yes

Quick and standard refunds for New Zealand equities are available on a case-by-case and “best efforts” basis.”

Tax-exempt beneficial owners

Yes

Relief at source of withholding tax is available only if the appropriate documentation is submitted to Clearstream Banking.

Note: New Zealand equities may not be held in Clearstream Banking on behalf of beneficial owners that are New Zealand residents for tax purposes. Clients are responsible for ensuring compliance with this restriction.