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Inland Revenue

Tax Policy

Reciprocal arrangements for international aircraft operations

Domestic law

International operations carried on by a non-resident aircraft operator are liable to New Zealand tax, to the extent that income from the operations is attributable to New Zealand.


Many of New Zealand's double tax agreements (DTAs) provide a full exemption from New Zealand income tax for aircraft operators of the other jurisdiction. In some DTAs only a partial exemption is provided.

Section CW 56 of the Income Tax Act 2007 provides that income earned by non-resident aircraft operators is exempt from New Zealand tax if the Commissioner is satisfied that a reciprocal exemption exists for New Zealand resident aircraft operators in the non-resident's home jurisdiction.

Full exemptions

Full exemptions under section CW 56 are currently in place with:

  • Brunei Darussalam;
  • Qatar; and
  • Solomon Islands.

Partial exemptions

Partial exemptions under section CW 56 are currently in place with:

  • Malta (leasing situations only, excluding those where a Maltese operator has an associated permanent establishment in New Zealand).

Requests for exemption

Requests for this exemption should be addressed to:

International Tax
Policy and Strategy
Inland Revenue
PO Box 2198
Wellington 6140

Requests should be accompanied by confirmation from the non-resident aircraft operator's home jurisdiction that, in corresponding circumstances, that jurisdiction would not tax the profits of a New Zealand resident aircraft operator in that jurisdiction.