Relief at source - eligibility, documentation, deadlines - New Zealand debt securities

19.02.2020

Who can obtain relief at source?

Exemption at source and relief at source from withholding tax on interest from New Zealand debt securities are available through Clearstream Banking for eligible beneficial owners as follows.

Standard debt securities (NRWT regime):

Eligible beneficial ownersRate applicable at source
Residents of Double Taxation Treaty DTT countriesTax treaty rate or 15%,
whichever is lower
Tax-exempt beneficial owners0%

Government debt securities (Approved Issuer Levy regime):

Eligible beneficial ownersRate applicable at source
Residents of Double Taxation Treaty DTT countriesTax treaty rate or 15%,
whichever is lower
Non-resident beneficial owners requesting the Approved Issuer Levy regime0%
Tax-exempt beneficial owners0%

Corporate debt securities (Approved Issuer Levy regime):

Eligible beneficial ownersRate applicable at source
Residents of Double Taxation Treaty DTT countriesTax treaty rate or 15%,
whichever is lower
Non-resident beneficial owners requesting the Approved Issuer Levy regime2%
Tax-exempt beneficial owners0%

Qualified corporate debt securities (Approved Issuer Levy regime):

Eligible beneficial ownersRate applicable at source
Residents of Double Taxation Treaty DTT countriesTax treaty rate or 15%,
whichever is lower
Non-resident beneficial owners requesting the Approved Issuer Levy regime0%
Tax-exempt beneficial owners0%

Documentation requirements

Documentation requirements vary according to the regime applicable to the debt securities and to the type of beneficial owner, as follows:

Debt securities governed by the Approved Issuer Levy regime:

  • Non-resident beneficial owners requesting the Approved Issuer Levy regime:
    • One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime;
    • Addendum to One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime (if applicable).
  • Tax-exempt beneficial owners:
    • One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime;
    • Addendum to One-Time Certification for New Zealand Government Debt Securities and other New Zealand Domestic Debt Securities governed by the Approved Issuer Levy regime (if applicable);
    • Certificate of Exemption.
  • Non-residents of Double Taxation Treaty (DTT) countries requesting NRWT:
    • One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
    • Certificate of Residence (upon request).

Standard debt securities governed by the Non-Resident Withholding Tax (NRWT) regime:

  • Residents of Double Taxation Treaty (DTT) countries:
    • One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
    • Breakdown of Holding (if applicable);
    • Certificate of Residence (upon request);
  • Tax-exempt beneficial owners:
    • One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt Securities;
    • Certificate of Exemption;
    • Breakdown of Holding (if applicable).

Form descriptions are presented according to the procedures available for relief and/or reclaim of withholding tax on income from New Zealand debt securities.

Deadlines for receipt of documents

Documentation for relief at source from withholding tax on interest on New Zealand debt securities must be received by Clearstream Banking by the following dates:

DocumentDeadline for receipt by Clearstream Banking
One-Time Certification for NZ Government Debt Securities and other NZ Domestic Debt Securities governed by the Approved Issuer Levy regimeAt the latest, three business days before the record date of the first interest payment by 10:00 CET.
Addendum to One-Time Certification for NZ Government Debt Securities and other NZ Domestic Debt Securities governed by the Approved Issuer Levy regimeAt the latest, three business days before the record date of the relevant interest payment by 10:00 CET.
One-Time Certification for Non-Resident Withholding Tax (NRWT) Regime on New Zealand Domestic Debt SecuritiesAt the latest, three business days before the record date of the first interest payment by 10:00 CET.
Certificate of ExemptionAt the latest, three business days before the record date of the first interest payment by 10:00 CET.
Breakdown of HoldingAt the latest, three business days before the record date of the relevant interest payment by 10:00 CET.
Certificate of ResidenceUpon request.

N.B.: In the case of New Zealand Treasury Bills, the above certification must be received by Clearstream Banking by mail not later than five business days before the record date of the first interest payment by 10:00 CET.

The New Zealand Central Securities Depository (NZCSD) may charge a fee for any tax adjustments received by Clearstream Banking after the above-mentioned deadlines. This fee will be passed on to customers who send late instructions.