Relief at source - eligibility, documentation, deadlines - New Zealand debt securities
Who can obtain relief at source?
Exemption at source and relief at source from withholding tax on interest from New Zealand debt securities are available through Clearstream Banking for eligible beneficial owners as follows.
Standard debt securities (NRWT regime):
| Eligible beneficial owners | Rate applicable at source |
Residents of Double Taxation Treaty DTT countries | Tax treaty rate or 15%, whichever is lower |
Tax-exempt beneficial owners (a) | 0% |
New Zealand tax-exempt beneficial owners | 0% |
a. Non-residents tax-exempt beneficial owners granted tax-exempt status by the New Zealand Inland Revenue Department.
Government debt securities (Approved Issuer Levy regime):
| Eligible beneficial owners | Rate applicable at source |
Residents of Double Taxation Treaty DTT countries | Tax treaty rate or 15%, whichever is lower |
Non-resident beneficial owners requesting the Approved Issuer Levy regime | 0% |
Tax-exempt beneficial owners (a) | 0% |
New Zealand tax-exempt beneficial owners | 0% |
a. Non-residents tax-exempt beneficial owners granted tax-exempt status by the New Zealand Inland Revenue Department.
Corporate debt securities (Approved Issuer Levy regime):
| Eligible beneficial owners | Rate applicable at source |
Residents of Double Taxation Treaty DTT countries | Tax treaty rate or 15%, whichever is lower |
Non-resident beneficial owners requesting the Approved Issuer Levy regime | 2% |
Tax-exempt beneficial owners (a) | 0% |
New Zealand tax-exempt beneficial owners | 0% |
a. Non-residents tax-exempt beneficial owners granted tax-exempt status by the New Zealand Inland Revenue Department.
Qualified corporate debt securities (Approved Issuer Levy regime):
| Eligible beneficial owners | Rate applicable at source |
Residents of Double Taxation Treaty DTT countries | Tax treaty rate or 15%, whichever is lower |
Non-resident beneficial owners requesting the Approved Issuer Levy regime | 0% |
Tax-exempt beneficial owners (a) | 0% |
New Zealand tax-exempt beneficial owners | 0% |
a. Non-residents tax-exempt beneficial owners granted tax-exempt status by the New Zealand Inland Revenue Department.
Kauri bonds:
Clearstream Banking applies 0% withholding tax by default for the above-mentioned securities.
Beneficial owners that are recognised by the New Zealand Inland Revenue Department (IRD) as having the Resident Withholding Tax (RWT) exempt status must provide their details including the IRD number to Clearstream Banking in order to be eligible for the 0% rate.
Documentation requirements
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 New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime;
- 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).
Form descriptions are presented according to the procedures available for relief and/or reclaim of withholding tax on income from New Zealand debt securities.
Deadlines for receipt of documents
Documentation for relief at source from withholding tax on interest on New Zealand debt securities must be received by Clearstream Banking by the following dates:
| Document | Deadline for receipt by Clearstream Banking |
One-Time Certification for NZ Government Debt Securities and other NZ Domestic Debt Securities governed by the Approved Issuer Levy regime | At the latest, three business days before the record date of the first interest payment by 10:00 CET. |
Addendum to One-Time Certification for NZ Government Debt Securities and other NZ Domestic Debt Securities governed by the Approved Issuer Levy regime | At the latest, three business days before the record date of the relevant interest payment by 10:00 CET. |
One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities | At the latest, three business days before the record date of the first interest payment by 10:00 CET. |
Certificate of Exemption | At the latest, three business days before the record date of the first interest payment by 10:00 CET. |
Breakdown of Holding | At the latest, three business days before the record date of the relevant interest payment by 10:00 CET. |
Certificate of Residence | Upon request. |
The New Zealand Central Securities Depository (NZCSD) may charge a fee for any tax adjustments received by Clearstream Banking after the above-mentioned deadlines. This fee will be passed on to customers who send late instructions.