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Inland Revenue

Tax Policy

PUBLISHED 13 November 2010

NZ-US double tax agreement comes into force

The updated double tax agreement between New Zealand and the United States signed on 1 December 2008 has come into force. The agreement includes lower withholding taxes on dividends, interest and royalty payments between the two countries. For more information see the media statement and the text of the agreement.

Hon Peter Dunne
Minister of Revenue

Dunne: Updated NZ-US double tax agreement now in force

The protocol that updates the double tax agreement between New Zealand and the United States is now in force, Revenue Minister Peter Dunne announced today.

Both countries have now exchanged diplomatic notes, bringing the new agreement into force.

The protocol amends the 1983 agreement between the two countries. "As well as generally modernising the treaty, the new agreement will deliver lower withholding tax rates on dividends, interest and royalties between New Zealand and the United States," Mr Dunne said.

The new withholding tax rates will apply from 1 January 2011. For New Zealand taxes other than withholding taxes, the protocol will apply for income years beginning on or after 1 April 2011. For United States taxes other than withholding taxes, the protocol will apply for taxable periods beginning on or after 1 January 2011.

"This is an important development that will benefit both countries by helping to reduce tax barriers to two-way trade and investment," Mr Dunne said.

"Lower withholding tax rates will make it less costly for businesses in one country to invest in the other, and to bring profits home for reinvestment or distribution to shareholders."

The withholding tax rate on dividends is reduced from a standard rate of 15% to 5% for an investing company that has at least a 10% shareholding in the company paying the dividend. It is further reduced to 0% if the investing company holds 80% or more of the shares in the other company and meets other criteria.

The withholding rate on royalties is reduced from 10% to 5%. The rate on interest will generally remain at 10%, although it drops to 0% for interest paid to lending or finance businesses, provided that the 2% Approved Issuer Levy is paid on New Zealand-sourced interest.

The United States is New Zealand's third largest export market and third largest source of imports. It is second only to Australia as a source of foreign direct investment into New Zealand and as a direct investment destination for New Zealanders.

New Zealand currently has 35 double tax agreements in force with our main trading and investment partners.

The text of the new double tax agreement is available at


Mark Stewart | Press Secretary | Office of Hon Peter Dunne
Cell +64 21 243 6985