New Zealand as an Investor/Investee Country : Trust Taxation

Sections 226 to 233 of the New Zealand Income Tax Act 1976 contain a special regime for the taxation of trusts. Income that is distributed by the trustee is taxed in the hands of the beneficiary, and income that is accumulate is taxed in the hands of the trustee. The regime contains a number of provisions that are designed to prevent people using trusts to avoid tax on New Zealand source income or to relieve New Zealand resident beneficiaries from tax they might otherwise have to pay. On the other hand, the regime is carefully crafted so that the mere fact of trustees’ being resident in New Zealand does not attract tax