New Zealands Approach to Pillar Two


  1. Revenue Threshold
  2. Capital Gains Election
  3. Tax Credits
  4. UPEs and Deductible Dividend Regimes
  5. Tax on Supplementary Dividends
  6. Anti-Inversion Rule
  7. Imputation Credit
  8. Domestic Minimum Tax
  9. Under-Taxed Payments Rule

Given New Zealand’s relatively small Pillar Two population, relatively high tax corporate income tax rate (28% under Schedule 1 of the Income Tax Act) and general lack of substantial tax incentives (other than for capital gains) Pillar Two is unlikely to be as significant in NZ as it is in certain other jurisdictions. It is expected that 20-25 NZ MNEs will be within its scope. 

Nevertheless, there are features of the NZ regime that raise issues from a Pillar Two perspective. Some of these were addressed in a Pillar Two consultation document issued earlier this year. 

In this article we look at some of the key issues in the implementation of Pillar Two for New Zealand.

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