Beneficial owners recognised in New Zealand

06.03.2015

The following types of beneficial owner are recognised for tax purposes in New Zealand:

  • Residents of Double Taxation Treaty (DTT) countries;
  • Non-residents requesting the Approved Issuer Levy regime;
  • Tax-exempt beneficial owners.

New Zealand securities may not be held in Clearstream Banking on behalf of beneficial owners that are New Zealand residents for tax purposes. Customers are responsible for ensuring compliance with this restriction.

Residents of Double Taxation Treaty (DTT) countries

For non-resident beneficial owners that benefit from a Double Taxation Treaty (DTT) between their country of residence and New Zealand, the taxation details vary by type of security, as follows.

  • Debt securities covered by the Approved Issuer Levy regime:

Relief at source is available to non-resident beneficial owners that qualify for the benefit of a reduced rate of:

  • Levy in accordance with the Approved Issuer Levy regime, as follows:
    • 0% on registered government debt securities;
    • 0% on qualified corporate debt securities; or
    • 2% on registered corporate debt securities;
    or
  • Withholding tax in accordance with a DTT between their country of residence and New Zealand.

If we do not receive the request for application of the Approved Issuer Levy 
regime before our stated deadline, the issue will be considered as a “Standard debt security” and the interest payment will be subject to the standard Non-Resident Withholding Tax (NRWT) rate for on debt securities not covered by the Approved Issuer Levy regime.

A quick refund of the relevant amount of withholding tax is available through Clearstream Banking if the beneficial owner has not obtained relief at source.

Customers can, by submitting the appropriate documentation, apply through us for a standard refund on behalf of beneficial owners for whom relief at source and quick refund have not been obtained.

  • Standard debt securities (non-Approved Issuer Levy) covered by the Non-Resident Withholding Tax (NRWT) regime:

The standard rate of NRWT on interest from New Zealand standard debt securities is 15%.

Relief at source is available to non-resident beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and New Zealand.

A quick refund of the relevant amount of withholding tax is available through Clearstream Banking if the beneficial owner has not obtained relief at source.

Customers can, by submitting the appropriate documentation, apply through us for a standard refund on behalf of beneficial owners for whom relief at source and quick refund have not been obtained.

Note: The maximum rate of withholding tax is defined in the relevant DTT.

  • Equities:

The standard rate of Non-Resident Withholding Tax (NRWT) on dividends from New Zealand equities is 30%.

Relief at source is available to beneficial owners that qualify for the benefit of a reduced rate of withholding tax in accordance with a DTT between their country of residence and New Zealand.

A quick refund of the relevant amount of withholding tax is available through Clearstream Banking if the beneficial owner has not obtained relief at source.

Customers can, by submitting the appropriate documentation, apply through us for a standard refund on behalf of beneficial owners for whom relief at source and quick refund have not been obtained.

Non-residents requesting the Approved Issuer Levy regime

For non-residents of New Zealand requesting the Approved Issuer Levy regime, the taxation details vary by type of security, as follows.

  • Debt securities covered by the Approved Issuer Levy regime:

Relief at source is available to non-residents that qualify for the benefit of a reduced levy in accordance with the Approved Issuer Levy regime, as follows:

  • 0% on registered government debt securities;
  • 0% on qualified corporate debt securities; or
  • 2% on registered corporate debt securities.

If we do not receive the request for application of the Approved Issuer Levy regime before our stated deadline, the issue will be considered as a “Standard debt security” and the interest payment will be subject to the standard Non-Resident Withholding Tax (NRWT) rate for on debt securities not covered by the Approved Issuer Levy regime, which is currently 15%.

Customers can, by submitting the appropriate documentation, apply through us for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.

  • Standard debt securities (non-Approved Issuer Levy, covered by the Non-Resident Withholding Tax (NRWT) regime):

The standard rate of NRWT on interest from New Zealand standard debt securities is 15%.

Neither relief at source nor standard refund is available to a non-resident requesting the Approved Issuer Levy regime unless such beneficial owner qualifies as a DTT resident.

  • Equities:

The standard rate of Non-Resident Withholding Tax (NRWT) on dividends from New Zealand equities is 30%.

Neither relief at source nor standard refund is available to a non-resident requesting the Approved Issuer Levy regime unless such beneficial owner qualifies as a DTT resident.

Tax-exempt beneficial owners

The taxation details for tax-exempt beneficial owners vary by type of security, as follows.

  • Debt securities covered by the Approved Issuer Levy (AIL) regime:

Exemption at source is available beneficial owners that have been granted tax-exempt status by the New Zealand Inland Revenue Department.

Customers can, by submitting the appropriate documentation, apply through Clearstream Banking for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.

  • Standard debt securities (non-Approved Issuer Levy, covered by the Non-Resident Withholding Tax (NRWT) regime):

The standard rate of NRWT on interest from New Zealand standard debt securities is 15%.

Exemption at source is available beneficial owners that have been granted tax-exempt status by the New Zealand Inland Revenue Department.

Customers can, by submitting the appropriate documentation, apply through Clearstream Banking for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.

  • Equities:

The standard rate of Non-Resident Withholding Tax (NRWT) on dividends from New Zealand equities is 30%.

Exemption at source is available beneficial owners that have been granted tax-exempt status by the New Zealand Inland Revenue Department.

Customers can, by submitting the appropriate documentation, apply through Clearstream Banking for a standard refund on behalf of beneficial owners for whom relief at source has not been obtained.