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Inland Revenue

Tax Policy

Reciprocal arrangements for international shipping operations

Domestic law

Sections CV 16 and YD 6 of the Income Tax Act 2007 deem 5% of the gross amount earned by a non-resident shipping operator from shipping cargo, mail or passengers from a New Zealand port to a foreign port to be taxable in New Zealand.


Most of New Zealand's double tax agreements provide that the income will be exempt for shipping operators of the other jurisdiction.

In addition, sections CV 16 and YD 6 of the Income Tax Act 2007 effectively provide that the income will be exempt if the Commissioner is satisfied that a reciprocal exemption exists for New Zealand resident shipping operators in the non-resident's home jurisdiction. An exemption under this provision is currently in place with:

  • Barbados
  • Bermuda
  • Brazil
  • Cayman Islands
  • Greece
  • Israel
  • Liberia
  • Netherlands Antilles
  • New Caledonia
  • Panama
  • Tonga
  • Vanuatu

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 shipping operator's home jurisdiction that, in corresponding circumstances, that jurisdiction would not tax the profits of a New Zealand resident shipping operator in that jurisdiction.