New Zealand resident companies are taxed on their worldwide income, and non-resident companies (including branches) are taxed on their New Zealand-sourced income, subject to any applicable DTA.
The New Zealand corporate income tax (CIT) rate is 28%.
Implementation of the Global Anti-Base Erosion (GloBE) Rules
It is expected that New Zealand will implement the GloBE Rules, a key component of the OECD’s Two-Pillar Solution to address the tax challenges of digitalisation of the economy, once a 'critical mass' of other countries have also implemented the rules.
Depending on the timing of adoption in other countries, the government proposes to adopt the following elements of the GloBE Rules:
- The Income Inclusion Rule (IIR), which could apply for income years starting as early as 1 January 2024. This rule would apply to New Zealand headquartered multinationals and New Zealand entities that are subsidiaries of a foreign-headquartered multinational located in a jurisdiction that has not implemented this rule (where the New Zealand subsidiary has subsidiaries outside of New Zealand).
- The Undertaxed Profits Rule (UTPR), which could apply for income years starting as early as 1 January 2025. Where the IIR applies, the UTPR will apply to foreign multinationals that operate in New Zealand.
In addition, the government proposes a 15% domestic minimum tax that would apply to New Zealand headquartered multinational groups that are within the scope of the rules and that have 'undertaxed' income in New Zealand. Unlike many other jurisdictions, New Zealand’s domestic minimum tax is not proposed to apply to foreign-owned New Zealand subsidiaries.
The global minimum tax and the domestic minimum tax will apply to large multinationals with annual global revenue of 750 million euros (EUR) (approximately NZD 1.3 billion) or more, subject to certain exemptions.
Local income taxes
There are no state or municipal income taxes in New Zealand.