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Inland Revenue

Tax Policy

PUBLISHED 2 April 2019

NZ signs new DTA with China

A new Double Tax Agreement between the People’s Republic of China and New Zealand was signed in Beijing yesterday.

The agreement will promote economic ties between the two countries. It reduces the withholding tax rates imposed on certain dividends. It also eliminates the risk of double taxation.

The new DTA is New Zealand’s first to be signed following the completion of the work on base erosion and profit shifting (BEPS) and the release of the 2017 update of the OECD Model Tax Convention and contains new anti-BEPS measures.

For more information see the Minister of Revenue’s media statement and the text of the DTA.

Hon Stuart Nash
Minister of Revenue

1 April 2019

Media statement

NZ-China economic ties strengthened

Economic ties between New Zealand and China are being strengthened with the successful negotiation of a new taxation treaty.

The double tax agreement was signed by New Zealand’s Ambassador to China and by the Commissioner of the State Taxation Administration of China, at a signing ceremony in Beijing witnessed by the Prime Minister.

“An update to the existing Double Tax Agreement (DTA) will reduce barriers to cross-border trade and investment,” says Revenue Minister Stuart Nash.

“DTAs provide greater certainty of tax treatment, especially for cross-border investment flows such as dividends, interest, and royalties. The new DTA will reduce the withholding rates on certain dividends and eliminate double taxation.

“The new agreement also enhances the ability of both countries to detect and prevent tax evasion. It will contribute to the overall integrity of the New Zealand tax system.

“China is New Zealand’s largest trading partner in goods and one of our largest investment partners. Anything we can do to cooperate and smooth business between our two nations is hugely valuable.

“The new tax agreement is also significant in the ongoing fight against base erosion and profit shifting (BEPS) by multinationals. Significantly, this tax agreement with our largest trading partner will also include new anti-BEPS measures. These include measures to prevent companies structuring their activity to avoid taxation on profits.

“Double tax agreements make it less costly for a business in one country to do business and invest in the other” says Mr Nash.

The new DTA replaces a 1986 agreement with a more modern set of rules and ensures that our bilateral framework for taxing cross-border economic activity remains up to date and fit for purpose. It will be brought into force through an exchange of diplomatic notes with China.

The text of the agreement can be found at