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Form descriptions - Relief at source - New Zealand debt securities

10.01.2023

Information is provided here about the forms and their use in relation to the procedure for relief at source from withholding tax on income from New Zealand debt securities.

Documentation requirements vary according to the regime applicable to the debt securities and to the type of beneficial owner, as follows:

Debt securities governed by the Approved Issuer Levy regime:

Non-resident beneficial owners requesting the Approved Issuer Levy regime:
- One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime;
- Breakdown of holding (if applicable);
- Addendum to One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime (if applicable).
Tax-exempt beneficial owners:
- One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime;
- Breakdown of holding (if applicable);
- Addendum to One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime (if applicable);
- Certificate of Exemption.
Residents of Double Taxation Treaty (DTT) countries requesting NRWT:
- One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
- Breakdown of holding (if applicable);
- Certificate of Residence (upon request).
Beneficial owners, residents for tax purposes in New Zealand, or not residents in New Zealand but with a permanent establishment in New Zealand, recognised by the New Zealand Inland Revenue Department (IRD) as having the Resident Withholding Tax (RWT) exempt status:
- One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime;
- Breakdown of Holding (when applicable).

Standard debt securities governed by the Non-Resident Withholding Tax (NRWT) regime:

Residents of Double Taxation Treaty (DTT) countries:
- One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
- Breakdown of Holding (if applicable);
- Certificate of Residence (upon request).
Tax-exempt beneficial owners:
- One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
- Certificate of Exemption;
- Breakdown of Holding (if applicable).
Beneficial owners, residents for tax purposes in New Zealand, or not residents in New Zealand but with a permanent establishment in New Zealand, recognised by the New Zealand Inland Revenue Department (IRD) as having the Resident Withholding Tax (RWT) exempt status:
- One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
- Breakdown of Holding (when applicable)

Kauri bonds:

Clearstream Banking applies 0% withholding tax by default for the above-mentioned securities.

Beneficial owners, residents for tax purposes in New Zealand, or not residents in New Zealand but with a permanent establishment in New Zealand, recognised by the New Zealand Inland Revenue Department (IRD) as having the Resident Withholding Tax (RWT) exempt status:
Breakdown of Holding (when applicable).

One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime

Customers who want to have the Approved Issuer Levy regime applied for their account or for the account of the beneficial owner must provide Clearstream Banking with a One-Time Certification.

How many are provided?	One per Clearstream Banking account.
Who completes it?	Customer.
How often is it provided?	Once. Valid until revoked.
When is it provided?	At the latest three business days before the record date of the first interest payment by 10:00 CET.
Copy or original?	Original required.

Addendum to One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy Regime

Customers who want to exclude, for a specific interest due date, all or part of their holdings from the One-Time Certification and who prefer instead to apply for the normal NRWT regime, either on their own behalf or on behalf of their beneficial owners, should complete the Addendum to One- Time Certification.

How many are provided?	One per interest payment.
Who completes it?	Customer.
How often is it provided?	Per interest payment.
When is it provided?	At the latest three business days before the record date of the relevant interest payment by 10:00 CET.
Copy or original?	Original required.

One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities

Customers who want to apply for the NRWT regime, either on their own behalf or on behalf of their beneficial owners, should complete the One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities.

How many are provided?	One per Clearstream Banking account.
Who completes it?	Customer.
How often is it provided?	Once. Valid until revoked.
When is it provided?	At the latest three business days before the record date of the first interest payment by 10:00 CET.
Copy or original?	Original required.

Certificate of Exemption

Customers who want to apply for tax exemption, either on their own behalf or on behalf of their beneficial owners, should provide a certificate that indicates the tax-exempt status of the beneficial owner of the securities as granted in the letter by the New Zealand Tax Authorities.

Eligible beneficial owners must contact the New Zealand Tax Authorities and submit an application to request recognition. Once a favourable Certificate of Exemption is issued, a copy should be sent to Clearstream Banking.

How many are provided?	One per beneficial owner.
Who completes it?	The New Zealand Tax Authorities.
How often is it provided?	Once. Valid until revoked (or until the expiry date).
When is it provided?	At the latest three business days before the record date of the first interest payment by 10:00 CET.
Copy or original?	Original or authenticated copy required.

Breakdown of Holding

A Breakdown of Holding must be submitted, via Swift MT599 “Attention: SIT - Tax Services Singapore” and must indicate:

Clearstream customer’s account number;
ISIN code;
Payment date;
Corp. event ID;
Total holding for the event,
The holding for non-residents with the respective tax rate to be applied,
The holding for NZ tax exempt residents with the respective tax rate to be applied,
And, for beneficial owners that are residents for tax purposes in New Zealand or, not residents in New Zealand but with a permanent establishment in New Zealand, recognised by the New Zealand IRD as having the RWT exempt status:
- Full name of the beneficial owners,
- Full address of the beneficial owners (complete street address including postal code, city, country),
- IRD Tax Identification Number.
And, for entities, not resident for tax purpose in New Zealand, granted tax-exempt status by the New Zealand IRD:
- The full name of the beneficial owners,
- The full address of the beneficial owners (complete street address including postal code, city, country).

All these declared positions must be accurate at 19:00 CET on the relevant record date. If there is a discrepancy between the declared positions and the customer’s total holding visible in Clearstream Banking’s books, the customer’s application for reduced rates or tax exemption will be rejected and, consequently, the maximum standard tax rate will be applied.
Furthermore, if no Breakdown of Holding is received by Clearstream Banking by the prescribed deadline, the customer’s total holding will be considered as uncertified and, as a consequence, the maximum standard tax rate will be applied.

How many are provided?	One per Clearstream Banking account.
Who completes it?	Customer.
How often is it provided?	Per interest payment.
When is it provided?	At the latest, three business days before the record date of the first interest payment by 10:00 CET.
Copy or original?	Original. Via Swift message MT599 (“Attention to SIT - Tax Services Singapore”).

Certificate of Residence

A Certificate of Residence, with the beneficial owner's full name and address, issued by the beneficial owner's tax authorities.

How many are provided?	One per beneficial owner.
Who completes it?	Beneficial owner’s tax authorities.
How often is it provided?	Upon request.
When is it provided?	Upon request.
Copy or original?	Original required.

Form descriptions are presented according to the procedures available for relief and/or reclaim of withholding tax on income from New Zealand debt securities.