New Zealand has also just introduced a settlor trust regime similar to that operating in North America. The object is to catch accumulations of income offshore which could be remitted to New Zealand as taxed capital. Essentially, New Zealand settlers are liable for tax on the income received by an offshore trustee as if the resident settlor was an agent of the trustee. Providing the appropriate rate of New Zealand tax is paid on offshore trusts with New Zealand settlers, any after tax funds or capital of those trusts may be remitted tax free to New Zealand. New Zealand has recently altered its rates of domestic taxation.
Special rules apply to mining and petroleum exploration companies.
There are no thin capitalization rules in New Zealand where debt rather than equity capital is contemplated, but non-resident withholding tax and international profit shifting avoidance rules may apply to interest remitted from New Zealand. There has always been a land tax in New Zealand but the regime has recently been altered to broaden the tax base applying. The Reserve Bank does, however, have the residual ability to control a non-resident's account should it be seen as necessary to do so to protect New Zealand's interests. Specific currency exposure limits continue to apply to financial institutions licensed to deal in foreign exchange. Remittance of interest, profits, dividends and royalties requires no approval nor does repatriation of non-resident capital, capital gains and capitalized profit.