Australia - New Zealand Tax treaty

The 2009 tax treaty between Australia and New Zealand entered into force 19 March 2010 and will apply for withholding tax purposes as from 1 May 2010.

A 0% tax rate will apply to dividends paid to a company that owns, directly or indirectly, 80% or more of the voting power of the payer company for a 12-month period (certain other criteria also will need to be fulfilled).

The tax rate will be 5% where the beneficial owner is a company that holds directly at least 10% of the voting power in the payer company. Tax rate in all other cases will be 15%.

The withholding tax rate on interest will generally remain at 10%, although an exemption will apply to interest derived by a "financial institution" that is unrelated to and dealing wholly independently with the payer. Tax rate on royalties is reduced from 10% to 5%.