The course will address:

1. the tax/compliance risks of New Zealand tax residents investing in partnerships/look-through entities established outside of New Zealand.
2. The tax/compliance risks of non-residents investing into limited partnerships formed in New Zealand.

Migration to New Zealand generally triggers a transitional tax residence exemption which exempts foreign passive income from income tax in New Zealand for a period of 48/54 months. Migrants with look-through entities (e.g. US LLCs, German GmbH & Co KG) might be exposed to taxation from the day of arrival.

Foreign living wills or family partnerships (e.g. German GmbH & Co KG) are instruments which reduce tax exposure in the jurisdiction of establishment. However, these entities might trigger significant dividend taxation or general residence issues in New Zealand.
New Zealand Limited Partnerships with foreign limited partners will trigger a tax obligation in New Zealand. The offshore limited partners need to apply their domestic rules and the Double Tax Agreements when determining taxation on/offshore.

Upon satisfactory completion of this activity, you will be able to:

• Understand the domestic and foreign rules applicable to these investments
• Identify the New Zealand compliance risks associated with these investments
• Recognise the application of the New Zealand rules and the impacts for clients involved
• Help clients to understand the advantages and disadvantages to ensure an informed decision can be made before migration or before investing
• Enable the application of Double Tax Agreements
• Assist offshore advisors to ensure compliance in both jurisdictions especially in family arrangements

Suited to:

• Tax Advisors
• Lawyers
• Senior Accountants

1.25 CPD hours

PRESENTER

Dr Peter Loerscher, Principal, Peter Loerscher International Tax Limited
Peter Loerscher  was previously (2005 to 2018) Inland Revenue’s Principal Advisor International Tax (SME). Peter is an accountant/tax specialist with a strong focus on international tax and is a well-known presenter.