Resident corporations and New Zealand branches of foreign corporations are generally required to withhold tax on payments of passive income. Rates on payments to non-residents under New Zealand's DTAs are set out in the table below.
The supplementary dividend tax credit regime applies only to fully imputed dividends paid to shareholders holding less than 10% of the shares in the company and NRWT rates of at least 15%.
An important exclusion from the dividend concepts is that amounts paid to shareholders on liquidation of a company will not be dividends (and therefore will not be subject to any tax, including WHT) to the extent they represent available subscribed capital (essentially paid-up share capital) plus net realised and unrealised capital gains in the company. This exclusion does not apply where the recipient shareholder is a non-resident company that is related to the New Zealand company paying the dividend.
Last Reviewed - 16 December 2019