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Pre-Migration planning
Before a person, or family, proceeds with a decision to migrate professional advice should be obtained to determine the opportunities which may exist. Advanced planning can provide major financial benefits.
New Zealand has a feature of its tax system which is of considerable benefit to a migrant to New Zealand, if implimented before you and your family move to New Zealand. The New Zealand Foreign Trust (NZFT) regime recognises a trust (formed by a non-NZ resident) with investments outside New Zealand, has no tax obilgations or liability in New Zealand. Other tax jurisdictions often classify a NZFT as not being taxable in their tax system, if the NZFT has a New Zealand trustee, and it will have no tax liability in New Zealand.
Once a person/family has migrated to New Zealand, having a substantial portion of their assets in a NZFT, no tax will be payable on income earned by the NZFT (if invested outside of NZ) for up to 12 months from the date of the settlor of the NZFT becoming tax resident in NZ.
A major pre-migration planning opportunity exists for a migrant to NZ to transfer all of their assets, not in NZ, to a NZFT before moving to NZ and electing to have the NZFT become a Qualifying Trust in NZ within 12 months of settling in NZ. No tax is payable in NZ on the NZFT assets or foreign income earned up to the date of election. This is a signifacant opportunity given the NZ Gift Duty (tax) regime.
For more information please contact Charles Fletcher.
New Zealand Foreign Trusts for Investment
The use of a NZFT, for investment outside of New Zealand, can provide a major tax planning opportunity for International Investors. New Zealand has Double Tax Agreements with many 'mature' tax jurisdictions and some of those jurisdictions do not recognise a properly structured NZFT for tax purposes locally, with the result that a very low tax rate may apply to investments made by the NZFT, and no tax will be payable in New Zealand.
With effect from 1 October 2006, disclosure rules apply to NZ Foreign Trusts . NZ resident trustees are required to keep records relating to every NZFT, for tax purposes and to disclose certain information to the NZ Inland Revenue. NZ Inland Revenue has double tax agreements with 36 other countries and tax information exchange agreements with 18 other countries. These reciprocal arrangements may modify the tax treatment of some international transactions
For more information please contact Charles Fletcher.
Trustee Service
Fletcher Law, through its wholly owned Euro Trustee Corporation Limited, offers a professional trustee service for non-resident clients who have a trust which may benefit from utilising a New Zealand based trustee.
In conjunction with a clients other professional advisors, the trustee service is carefully designed to meet a specific need or purpose. You or your professional can contact us to consider the benefits of what Fletcher Law can offer.
International business
As a result of his considerable business experiences and contacts in Australia, South Africa, United States of America, England and some parts of Europe, Charles Fletcher can offer an unique service to:
New Zealand based clients seeking to do business off shore, International clients seeking to do business in, or through, New Zealand.
If you have any enquiries please:
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