Double Tax Agreements
New Zealand has a network of 38 double tax agreements (DTA’s) with foreign jurisdictions [See below table for current DTA countries]. New Zealand has also entered into numerous exchange of information agreements.
|Canada||India||Papua New Guinea||Thailand|
|Czech Republic||Italy||Russian Federation||United Kingdom|
Double Tax Relief
Credit is levied either in accordance with the applicable DTA or in accordance with the domestic law, in cases where no DTA is in force. The credit is limited to the lesser of the New Zealand income tax payable on the foreign income or the foreign income tax actually paid.
Foreign income tax must have been paid, and not merely be payable, before a credit is granted. Consequently the rate of exchange that must be used for converting the foreign tax into New Zealand dollars is generally the rate applying at the time the tax was paid.
All of New Zealand’s DTAs allow New Zealand residents a credit against New Zealand tax for tax paid in the treaty partner country, but not, in the case of dividends to which imputation credits in foreign country are attached.