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Inland Revenue

Tax Policy

PUBLISHED 28 November 2023

Austria second protocol signed

New Zealand and Austria have signed the Second Protocol updating the double tax agreement (DTA) and First Protocol between the two countries.

New Zealand entered negotiations with Austria for the Second Protocol to satisfy a ‘most favoured nation’ (MFN) clause in the existing DTA, which was triggered in 2010 after NZ agreed to lower dividend withholding rates with the United States and Australia. The Second Protocol extends the same dividend tax treatment to Austria.

In addition, the Second Protocol updates the existing DTA to include the most recent OECD anti-abuse provisions and several other minor changes. The Second Protocol will enter into force after both countries have completed the necessary domestic procedures, which in New Zealand's case will require an Order in Council.

Austria DTA