New Zealand

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 - Global Minimum Tax

New Zealand has enacted legislation to implement the GloBE Rules, a key component of the OECD’s Two-Pillar Solution to address the tax challenges of digitalisation of the economy. The legislation includes the following:

• The Income Inclusion Rule (IIR), which applies for income years beginning on or after 1 January 2025. This rule applies 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 applies from 1 January 2025 also. Where no IIR applies, the UTPR will apply to foreign multinationals that operate in New Zealand.
• The Domestic Income Inclusion Rule (DIIR), which applies to New Zealand headquartered multinational groups only from 1 January 2026. 

These rules will impact large multinationals with annual global revenue of 750 million euros (EUR) or more, subject to certain exemptions. This means, for multinational groups with a New Zealand presence (subsidiary, branch, or permanent establishment), additional compliance obligations will arise. These include:

• Registering with Inland Revenue to confirm the group falls within scope, within six months after the end of the first applicable tax year (e.g. by 30 June 2026 for December balance date groups);

• Filing an annual NZ ‘top-up’ tax return disclosing any top-up tax payable;

• Submitting the Pillar Two / GloBE Information Return, if the group files it in a jurisdiction that lacks an exchange of information agreement with New Zealand.

The potential NZD $100,000 penalty for failing to meet New Zealand Pillar 2 registration means New Zealand taxpayers should be making sure they have assessed whether registration is required, and completing the registration before the relevant due date if it is.

For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.

Local income taxes

There are no state or municipal income taxes in New Zealand.