Overview of wealth planning structures under New Zealand law.

Although New Zealand is not a tax haven, it is possible to establish New Zealand resident trusts which are exempt from New Zealand tax.

The key to the taxation of New Zealand trusts is the residence of the settlor rather than the residence of the trustees. The taxation of foreign settlor trusts with New Zealand trustees is codified in its taxation of trusts regime, and its trusts legislation.

In the typical case of a settlor gifting (non-New Zealand) assets into a New Zealand trust for the benefit of non-New Zealand beneficiaries the principal tax exemptions are as follows:

• Income Tax:
  None – provided there is no New Zealand source income.
• Capital Gains Tax:
  There is no capital gains tax in New Zealand.
• Inheritance or Succession Taxes:
  There are no inheritance taxes or succession taxes in New Zealand.

New Zealand enjoys the following features for international wealth planning purposes:

• A member of the OECD group of countries
• A normal tax paying jurisdiction
• A party to numerous Double Taxation Treaties
• A recognized trust law jurisdiction

What we do, continued

• Trustee Relationship
• Nature of an Exempt Trust
• International Aspects and Double Tax Agreement
• New Zealand Trust Structure
• New Zealand Tax Position
• Private Trustee Companies (PTC)
• New Zealand Limited Partnerships (LP)
• Confidentiality and Reporting Requirements