Beyond borders

Considerations for individuals

A tax guide for internationally mobile people and business 1

1. Introduction 2. Moving to New Zealand 3. Investing in New Zealand Foreword Tax residence and offshore Let’s get started Immigration residence Overview Immigration work visa Foreign equities Key work visa categories Financial arrangements Superannuation Your own business Portfolio Investment Entities (PIEs)

4. Trusts 5. Contact KPMG Classification of trusts How we can help Managing trust status and distributions Issues for settlors leaving New Zealand 2

1 Introduction

“When you travel, remember that a foreign country is not designed to make you comfortable. It is designed to make its own people comfortable.”

Clifton Fadiman 3

1A Foreword

Tax rules are different in Moving countries can be a time of This guide has been designed to help significant upheaval. you become a little more familiar with each country – navigating New Zealand tax. Successful transition relies on the rules and associated establishing yourself in new employment Unexpected taxes, penalties, interest, compliance obligations and business, settling into a new home and other tax hooks all lie in wait for and integrating into the community, each the unsuspecting. can be one of the more of which can be fundamentally different This guide is not going to make you a to what you have been used to before complex and bewildering tax expert (leave that to us), but it will the move. parts of trying to relocate highlight some of the key issues that across a border. Tax and immigration if not managed you need to be aware of. It will also arm well, can add to the stress of an you with the right questions to ask your international move. KPMG advisor. If you are coming to New Zealand for the first time, or simply returning after a period away, on behalf of KPMG New Zealand, we welcome you to this part of the world. We look forward to helping make your transition here as comfortable as possible. 4

1B Let’s get started

International mobility At KPMG, we recognise the need to This Beyond Borders guide is broken help smooth the process of investing into three core chapters, each focused and business is vitally overseas, and attracting offshore talent on specific activities relevant to an important to the to New Zealand. Too often, effort and individual’s obligations: energy can be absorbed by dealing with —— Moving to New Zealand – New Zealand economy regulatory and tax requirements, instead tax and immigration residence and future prosperity. of being focused on the main purpose – relocating your family and career. —— Taxing your investments This includes individuals Our objective is to take these worries —— Trusts. or businesses coming away, freeing you up to focus on what is important to you. We have also included contact details for to New Zealand, and KPMG’s range of experts at the end of I am delighted to present this Beyond and their this guide to assist you with any specific Borders publication as a guide to help questions or issues you may have. businesses broadening inform you of some of the key issues you might face as you move to New Zealand. If you have a business either expanding their horizons offshore. This guide is aimed at providing some offshore or investing into New Zealand, initial information to individuals moving you may be interested in our companion to New Zealand and to arm you with guide – Beyond Borders guide the key questions that might need to be for businesses. considered to smooth your path. What ever your endeavours, I wish you well.

Rebecca Armour Tax – Partner KPMG New Zealand 5

2 Moving to New Zealand

If you are coming to live in New Zealand, there are a few things you need to know about your tax and immigration residence positions. This chapter will provide you with an overview of those essential facts. 6

2A Tax residence

You need to know Tax residence Day count test Permanent place of abode When moving to New Zealand, the single If you are in New Zealand for more than The permanent place of abode test New Zealand taxes biggest influence on your tax position 183 days in any 12 month period, you is not as clear-cut as the day count its residents on their will be your status as a New Zealand are treated as tax resident from the first test. Whether you have a ‘permanent worldwide income tax resident. A tax resident is taxed on of those days. It’s important to note the place of abode’ is primarily determined worldwide income, with a tax credit period in question is any rolling 12 month by whether you have a dwelling in Tax residence is not the allowed if taxes are paid overseas on period – not the tax year or calendar year. New Zealand that is available for your foreign sourced income. In contrast, use. Whether the property is directly same as your immigration You are considered to be in New Zealand a non-resident is taxable only on owned by you, or through a trust or residence status for ‘the day’ if you are here present in New Zealand-sourced income. company is not relevant to the test. New Zealand for any part of the day. Whether or not you are In addition, even if the property is Tax residence under New Zealand’s eligible for the transitional rented out to third parties, it could domestic rules is determined by resident exemption still be treated as available to you. If meeting one of two tests. you have a dwelling in New Zealand, The first test is a simple count of days. other factors will also be considered The second test considers whether such as your economic, family and you have an enduring connection to social ties to New Zealand. New Zealand based on the availability This test is determined by case law, of a dwelling, i.e. a permanent place of and will depend on your specific abode. These tests are outlined in more circumstances. As a consequence, detail below. this is a constant source of tension If you are also treated as tax resident in between taxpayers and Inland Revenue. another country, your New Zealand tax liabilities may be impacted by the existence of a double tax treaty. Your KPMG advisor can work through the implications of dual tax residence with you. 7

2A Tax residence

Transitional residence Implications of becoming Obligations for non-residents A special concession is available to tax resident Even if you are not tax resident in transitional residents. This group includes In section 3 we discuss the main tax New Zealand, you could still trigger a tax new migrants and New Zealanders regimes that apply to the taxation of liability here if you are in New Zealand returning after at least 10 years who international investments including more than either three or six months. have never had the benefit of transitional foreign equities, financial arrangements A non-resident individual is taxed in resident status before. and foreign superannuation if you are New Zealand on income from not eligible for the transitional resident employment services performed here. A transitional resident is exempt from exemption, or after the transitional tax on offshore investment income for If you are in New Zealand for less than period expires. four years. This creates a period in which three months, you are likely to be overseas investments can be reviewed exempt from tax. Also, if you are here and restructured. for 183 days or less in a 12 month period, you may be relieved from tax under a As a transitional resident you have the double tax agreement that New Zealand opportunity to implement tax planning has in place with the other country where strategies to help ensure your holdings you are tax resident. are tax efficient and to minimise the administration associated with your tax compliance obligations. Your KPMG advisor can help with this. 8

2B Immigration residence

You need to know Immigration residence Pathways to residence After residence Holding New Zealand immigration There are three main pathways for Many migrants maintain their original Whether or not you are eligible residence means that a migrant enjoys migrants to become a New Zealand citizenship while holding a New Zealand for immigration residence great freedom to be in New Zealand immigration resident: through Resident Visa. Under the current rules, in relation to travel, business activities employment, family relationships a migrant may be able to obtain New There are two stages of and employment. The two stages of or investment. Zealand citizenship after holding their immigration residence are: Resident Resident Visa for five years and have immigration residence When assessing eligibility for residence, Visa and Permanent Resident Visa. spent most of their all migrants must demonstrate they You must be a resident during that time. A Resident Visa allows unlimited travel have sound health and character. first before becoming a in and out of New Zealand for a fixed In addition, Immigration New Zealand Having New Zealand citizenship will New Zealand citizen period of time, and can be upgraded to a may also assess their employment, enable the individual to obtain a Permanent Resident Visa after 24 months. qualifications, work experience, New Zealand passport. English language competence, A Permanent Resident Visa never expires family connections in New Zealand, and is not subject to any conditions and investments made in New Zealand allows the holder to re-enter New Zealand and source of investment funds. as a permanent resident anytime. For some migrants, they may have more than one suitable pathway to residence. 9

2C Immigration work visa

You need to know Key visa categories General information With the world continuing to grow In general, work visa applicants need You can come to New Zealand as a global marketplace, companies, to demonstrate that: increasingly, have the ability to on a work visa —— They have the relevant qualification or transcend borders to expand, work experience for the position on develop and strengthen businesses. You can trigger tax residence offer; and whilst on a work visa This also provides significant opportunities for individuals wishing to —— There is no New Zealand resident or A work visa can provide a path make New Zealand their new home. citizen available or readily trainable for to a New Zealand Resident Visa the position on offer. Immigration plays a key part in fuelling New Zealand’s prosperity. New Zealand A work visa can be granted for variable immigration laws are designed to periods up to five years and may promote and support the movement of therefore trigger an individual’s tax a workforce that benefits New Zealand’s residency in New Zealand. economy and society. It recognises different business needs and provides a number of visa categories to allow foreign nationals to work in New Zealand. 10

Work visas

Key work visa categories

Working Holiday Study to Work Essential Skills Specific Purpose Long Term Skill Shortage Talent (Accredited Employer)

Available for people aged Available for most Most commonly applied Suitable for specialist Suitable for highly skilled No requirement on skill level, between 18 and 30 New Zealand graduates work visa category skilled workers workers with experience qualification and experience

Visa conditions are different First 12 months, no restrictions Employer must undertake Employer must demonstrate Employment must be for Employer must depending nationality on employment position Labour Market Checks specific purpose 24 months or more be Accredited

No restriction as to Following 24 months, Employee must have Employee must have Employee must have Employee must be paid employment position employment relevant to relevant qualification relevant qualification relevant qualification $55,000 or more qualification required and/or experience and/or experience and/or experience

Visa period generally Visa period generally Visa period generally Visa period subject to Visa period for Visa period for 12 months 12-36 months 12-24 months purpose of stay 30 months 30 months

No direct path to residence Pathway to residence under Pathway to residence under Pathway to residence Pathway to residence Pathway to residence the Skilled Migrant Category the Skilled Migrant Category if the Employer is under the Work to under the Work to New Zealand based Resident Category Resident Category 11

3 Investing in New Zealand and offshore

This chapter provides an overview of the main tax rules applying to investments held by a New Zealand tax resident. 12

3A Overview

You need to know Tax impact of being a Personal income Taxation of international New Zealand resident tax rates investments The New Zealand tax year runs If you are a New Zealand tax resident, Personal income tax is imposed at As a tax resident in New Zealand, your from 1 April to 31 March you will generally be subject to tax in marginal rates up to 33%, as shown investments in foreign companies may New Zealand on your worldwide income. in the table. be taxable, even if you do not receive any The top marginal tax rate in Non-residents are subject to tax in dividends or other income. New Zealand on income only if it has Income band Tax rate New Zealand is 33% and applies If you maintain foreign currency bank a New Zealand source. $0 to $14,000 10.5% to income over $70,000 accounts, loans or mortgages (known

The New Zealand tax year is from 1 April $14,001 to $48,000 17.5% collectively as financial arrangements), New migrants may not be taxed to 31 March. As this may differ from the $48,001 to $70,000 30% you may also be liable to tax on foreign on foreign investment income for tax years in other countries, different $70,001 and above 33% exchange fluctuation. four years information will need to be captured to Income derived from investments is calculate income earned and taxes paid While the rates themselves are not New Zealand does not have a added to your taxable income, and that may need to be included in a New exceptionally high in comparison with capital gains tax taxed at your marginal tax rate. The rules Zealand income tax return. other countries, the highest marginal applying to foreign equities and financial rate comes into effect from $70,000. How your investments might be If you are also treated as tax resident in a arrangements discussed in this guide do This means that the effective tax rate taxed when you are a tax resident country that has a double tax agreement not apply to non-residents. could be relatively high. with New Zealand, you may be relieved The rules for determining your from tax in New Zealand on your New Zealand does not have a capital New Zealand tax obligations in relation worldwide income. gains tax. However, gains that might to international investments are set out be considered to be capital gains are Where there is a double tax agreement in on the following pages. still taxed if they arise from financial place between New Zealand and another arrangements (discussed below). country, tie-breaker provisions will This can also apply if you are a trader, determine which country has the primary or if the asset was acquired for the taxing right as a result of your residence. dominant purpose of sale. 13

3B Foreign equities

You need to know Offshore share investments Foreign investment funds Fair dividend rate method New Zealand tax residents with Dividends paid by New Zealand companies The FDR method calculates income The FIF FDR regime taxes foreign investments in overseas shares need are subject to an imputation system. This as 5% of the market value of shares equities on an assumed 5% return to consider their tax position on an means that dividend income carries credits held on 1 April (at the start of each per annum annual basis. The timing of transactions, resulting from tax paid by the company, tax year). Only the 5% is taxed, even particularly around 31 March each year, which can be used by resident shareholders if actual income and gains from the Other calculation options are can also have a significant impact on against their personal tax liability on the shares exceeds this amount. your tax position. dividends. Any gain on sale is only taxed available and might give you a The 1 April measurement date for if held on revenue account. For example, better result The foreign investment fund (FIF) rules calculating the market value of if shares are actively traded or held as part apply to offshore equity investments investments subject to tax means that Whether or not an exemption of a business. held by New Zealand tax residents. shares acquired during the tax year will applies to your shares A FIF includes a share in a foreign By contrast, investment in foreign equities not always be taxed in the first year of company, units in a foreign unit trust will typically subject to the FIF regime. The ownership. Conversely, shares sold or mutual fund, and some interests in FIF rules calculate the amount of income to during the tax year will be taxed as if they foreign superannuation schemes or be attributed to the shareholding. Several were held for the full year. So the timing retirement plans. methods are available to calculate the of transactions around the end of the tax attributed income, but the default (and year (31 March) is important. In this section we focus on the most commonly used) method is the fair application of the FIF rules which apply Anti-avoidance rules ensure that shares dividend rate (FDR) method. where a New Zealand tax resident has bought and sold within a tax year are also a shareholding in a foreign company. If If income is calculated under the FIF regime, subject to tax. you have significant shareholdings in a this is the only income that is taxed from foreign company, you may be subject the foreign shares. This means, if income is to the rules applying to non-portfolio calculated under the FDR method, dividends shareholdings or controlled foreign and gains are not separately taxable. companies (CFCs). If that is the case, Some Australian shares that are listed on we recommend contacting your KPMG the ASX are exempt from the FIF regime advisor who can assist with this. and taxed in the same way as New Zealand shares (see further below). 14

3B Foreign equities

Alternative methods Minor total holdings Australian share exemption If the total return (income and gains) If the total cost of all foreign shares Shares are exempt from the FIF regime across an individual’s portfolio of foreign held is less than $50,000, income does if they are shares: shares is less than 5%, the comparative not get attributed under the FIF regime. —— In an Australian resident company value method can be used instead of In this case, dividends are taxable. (not unit trust). FDR. This taxes the actual dividends, as well as realised and unrealised gains —— Listed on the ASX. or losses, derived from the shares. This accounts for approximately 450 to However, if your portfolio makes an 500 of the top Australian shares. These overall loss, you cannot deduct or carry shares are exempt from the FIF rules, forward that loss. but taxed on dividends. 15

3C Financial arrangements

You need to know Overview Examples for 2016 tax year The financial arrangements rules If held for the entire 2016 tax year These rules apply to all financial calculate taxable income arising from (to 31 March 2016), the exchange arrangements, including bank financial arrangements. ‘Financial movement from holding these currencies accounts, debt securities arrangements’ is a broadly defined varies as to whether you would have and derivatives term that includes all bank accounts, a gain or loss. A loss may be deductible term deposits, bonds, debt securities , as long as there is a connection with an The income taxed can include mortgages and derivatives. The general income earning purpose. unrealised foreign exchange gains intention of the rules is to tax the total economic return from the financial Currency Fx Gain in tax year 2016 Whether you are eligible for the arrangements, spread over the life of the AUD 8% cash basis concession investment. For example, a USD bank USD 9% account would give rise to income from SGD 10% How to manage the volatility both interest and a foreign exchange created by these rules gain, or loss. EUR 14% GBP 5% CNY 3%

If you have liabilities in these currencies, it will be the opposite of the above, i.e. a debt in AUD may give rise to a deductible loss. 16

3C Financial arrangements

Spreading income Cash basis concession Income from a financial arrangement Income from financial arrangements can must be spread over the life of the be returned on a cash basis if you meet arrangement, and complex rules direct one of the following criteria: how to do this. The consequence is —— Absolute value of all financial that unrealised gains will typically be arrangements is $1,000,000 or less. taxed on an annual basis. If your total holdings are under certain thresholds, —— Absolute value of all income/ there is a concession allowing income expenditure on financial arrangements to be calculated on a cash basis, so only is $100,000 or less. realised gains are taxed. In either case, the difference between cash basis income and accrual income over the period since the financial arrangement was entered, must be less than $40,000. Regardless of whether you benefit from the cash basis concession, you will be taxed on the total return from your financial arrangements. The cash basis is only a timing benefit. This means you need to keep records to enable the income to be calculated when the financial arrangement matures or is sold. 17

3D Superannuation

You need to know Foreign superannuation Taxing foreign superannuation KiwiSaver An interest in a foreign superannuation For the most part, a withdrawal from Employees who are considered to Foreign superannuation scheme that is not a regular pension a foreign superannuation scheme or be ‘usually living in New Zealand’ schemes are generally taxed or an annuity is generally taxed transfer from a foreign scheme to a and New Zealand resident employers upon withdrawal upon withdrawal from the scheme. New Zealand or Australian scheme (or non-residents with a fixed A withdrawal includes a transfer will be taxable on a schedular basis establishment in New Zealand) Some foreign superannuation made to a New Zealand or Australian with the amount of the withdrawal that are subject to the provisions of the schemes are taxed under the superannuation scheme, but does not is subject to tax being dependent upon KiwiSaver Act. include transfers made from one foreign the number of years the individual is FIF regime You will not be eligible to join KiwiSaver superannuation scheme to another resident of New Zealand. if you hold a temporary, visitor, work or Whether or not your planned foreign superannuation scheme. Withdrawals from Australian student permit or if you are living overseas. withdrawal or transfer will A foreign superannuation scheme is superannuation schemes are exempt be taxed KiwiSaver is a form of semi-compulsory broadly defined as a trust or company from the taxing of foreign superannuation superannuation (retirement) savings in established for retirement savings. in New Zealand. New Zealand. This requires employees These rules will include most countries’ to contribute a minimum of 3% of the employment-related superannuation employee’s earnings and employers to schemes, although it will depend on their also contribute a minimum of 3%. The precise terms. It will typically include contributions are collected through the 401k plans from the US, and PEPs, SIPPs Inland Revenue Department and passed and ISAs from the UK. to private retirement savings vehicles (KiwiSaver funds). New (qualifying) employees are automatically enrolled (with some exemptions for certain employers). There is an opportunity for employees to opt out of KiwiSaver during the initial period of automatic registration (being 8 weeks after employment commences). 18

3E Your own business

You need to know Are you a transitional resident? Is your business a CFC? Management and control If you own a business overseas, you New Zealand’s CFC rules tax income of A company is treated as resident in Dividends from a foreign company will need to consider how your move a foreign company in the hands of its New Zealand if either the centre of will not be taxed if you are to New Zealand will impact on it. shareholders by imputing the income management or director control is here. directly to them where ownership levels Both of these tests are fact-specific and transitional resident If you are a transitional resident, are above. A company is a Controlled the outcome will depend on how you you will not be taxed on foreign foreign company (CFC) if it is controlled operate. For example, holding board New Zealand does not tax capital investment income for four years. This by five or fewer New Zealand residents, meetings overseas helps ensure director gains on sale of shares means foreign dividends, FIF income or if a New Zealand resident has de control is not exercised here – but will be (discussed earlier) and CFC income Whether or not your company is facto control. of limited benefit if, in fact, decisions are (discussed below) are not taxed during a CFC made in New Zealand. Determining the this period. Any remuneration for Shareholdings held by associated parties location of the centre of management services will still be taxable. are aggregated when working out Whether you exercise can be more difficult, as the answer may whether a company is a CFC. management and control in Even if you are not a transitional differ depending on whether day-to-day New Zealand resident, New Zealand does not have Income from a CFC will be attributed to or senior management is considered. a capital gains tax, so you will typically you in accordance with the CFC rules. The consequences of a company being not be taxable in New Zealand on sale There is an exemption from attributing tax resident in New Zealand can be of shares in a business. This could be CFC income from certain active significant. The company will become advantageous if you are planning to businesses carried on overseas. taxable on its worldwide income, subject exit your business. to DTA relief and credit for foreign taxes, and dividends will no longer be considered to be foreign income for transitional residents. 19

3F Portfolio Investment Entities (PIEs)

You need to know What is a PIE? Fund managers in New Zealand will Provided you have indicated the correct PIE is a widely held collective typically offer managed funds that tax rate, the tax paid by the PIE will be a investment vehicle meet the requirements to be a portfolio final tax. PIE income that is attributed to investment entity, or PIE. Such funds you, will not need to be included in your The maximum tax payable in a PIE must be widely-held and have restrictions tax return. The maximum PIE tax rate is (28%) is less than the top marginal on the minimum number of investors, 28%, so there may be a tax advantage to rate (33%) the maximum interest those investors investing through a PIE. can hold, and the types of investments Listed PIEs are taxed differently. They Tax paid by an unlisted PIE on your the fund makes. are taxed at 28% and impute dividends behalf is a final tax (if paid at the If you invest in an unlisted PIE, you will paid. The dividend is exempt, unless you correct rate) need to advise the fund manager of choose to include it in your return. You your PIE tax rate (called the Prescribed would only do this if your tax rate was Investor Rate, or PIR). This rate is lower than 28%. determined based on your previous two

years’ income. The fund will then account for tax on your behalf. 20

4 Trusts

This chapter looks at the main issues associated with offshore trusts when coming to, or living in, New Zealand. 21

4A Classification of trusts

You need to know Foreign or non-complying trust An offshore trust that makes a The recently An offshore trust will be classified distribution to a New Zealand resident requested an independent enquiry into as either a foreign or non- beneficiary will be classified as either a the foreign trust disclosure rules. foreign trust or a non-complying trust. complying trust As a result of the report, new rules have The distinction is important because been put in place to strengthen New it determines both the amount of the The main consideration is the tax Zealand’s disclosure requirements, distribution that is taxable, and the rate residence of the settlor(s) including by: at which it is taxed. A trust is a foreign Distributions from a non- trust if no settlor of the trust is, or has —— Increasing the initial registration complying trust are taxed at been, tax resident in New Zealand. requirements for foreign trusts, and 45% of any income or capital Distributions of income from a foreign allowing regulatory agencies to search gains distributed trust are taxed at the beneficiary’s the register. marginal tax rate. Distributions of capital —— Requiring foreign trusts to file an gains and corpus (the capital of the trust) annual return including foreign shares are tax-free. and details of distributions. If a settlor of the trust is resident in The Government is looking to implement New Zealand, the trust may be a non- the changes recommended from the complying trust. Distributions of both enquiry from the 2018 tax year. income and capital gains from a non- complying trust are taxed at 45%. 22

4B Managing trust status and distributions

You need to know Settlor becoming Ordering rules Need for historic records New Zealand resident Distributions from both foreign trusts If a foreign, or non-complying, trust An election needs to be If a settlor of a foreign trust becomes and non-complying trusts are taxed makes a distribution to a New Zealand considered when a settlor resident in New Zealand, an election depending on their composition – resident beneficiary, it may be necessary becomes resident must be made to bring the trust within income, capital gains or corpus. The to trace the history of income, gains and the New Zealand tax system. Failure to ordering rules dictate the composition past distributions. do so will mean that the trust becomes of a distribution for tax purposes. These How to manage distributions If the make-up of a distribution cannot a non-complying trust, with distributions rules deem income and accumulated from offshore trusts to manage be determined, it is assumed to be being taxed at 45%. The settlor may also income to be distributed before capital the beneficiaries’ tax entirely taxable. become liable to account for tax as agent gains. Corpus is the last to be distributed. of the trustee if any further settlements These rules can come into conflict are made. with the actual composition of a trust This election needs to be made within distribution – for example, even if a 12 months of the settlor becoming beneficiary is only entitled to capital tax resident, or ceasing to be a distributions, they may be deemed to transitional resident. receive income. The rigidity of these rules means it is possible to manage the distributions to determine how income and capital are distributed to different beneficiaries. 23

4C Issues for settlors leaving New Zealand

You need to know Exemption for foreign income Loss of complying status Overseas tax issues New Zealand taxes trusts based, in Overseas income being earned by Trusts are taxed differently in different What needs to be considered part, on the residence of the settlor. So the trust with no New Zealand tax countries. Some countries focus on the when a complying trust ceases when the settlor ceases to be resident, imposed can be a positive planning trustee, while others look through to to have a New Zealand resident it is possible that the trust may cease opportunity, but it is a double-edged beneficiaries. The consequence of this settlor to be taxed on foreign income. This can sword. If you return to New Zealand, is that trusts may complicate your tax happen when a trust has no New Zealand and become tax resident again, the trust affairs if you move to a new jurisdiction. You need overseas tax advice resident settlor at any time throughout will then become a non-complying trust It is important to seek advice in the if you leave New Zealand as a the income year – regardless of whether – with distributions of income and gains country you are moving to, and to work trustee or settlor the trustee is New Zealand resident. taxed at 45%. If you are the settlor of a with advisors who can manage the trust that holds foreign assets, and you complexity of multiple jurisdictions. There are some additional issues are going to become non-resident, you you need to consider when you need to manage these issues before the leave New Zealand if you are end of the tax year that you cease to be the settlor of a New Zealand New Zealand tax resident. complying trust 24

5 Contact us

A selection of experienced professionals offering skills and ideas that are second to none. 25

5A How we can help...

Tax issues become To help you, we have provided contact If in doubt, please contact details for people who can provide or Rebecca Armour who will make sure complicated when co-ordinate KPMG services based on that you are guided to the right person. geographic location within New Zealand, international borders are Contact details are available on the and the leaders of our specialist lines of following page. involved. KPMG has an business. The KPMG New Zealand team international network of can bring a wealth of global knowledge professionals who can and experience. We work regularly with the wider KPMG network and have help you to navigate the relationships with colleagues in many complexity and difficulties other jurisdictions. Our relationships give you access to expertise from both sides of doing business, or living of the border that you are working across and investing, in multiple – ensuring you can be well-advised, and leaving you free to focus on what is tax jurisdictions. important to you. Auckland Hamilton Rebecca Armour Arthur Jacobson Vina Hira Olive Wallis Robert Hill Tax – Partner Senior Tax Counsel Tax – Partner Tax – Partner Tax – Director T: (09) 367 5926 T: (04) 816 4831 T: (07) 858 6516 T: (03) 371 4834 T: (07) 571 1776 E: [email protected] E: [email protected] E: [email protected] E: [email protected] E: [email protected]

Business Advisory Financial Reporting Audit China Business Immigration Paul McPadden Havana Mar Ann Tod Greg Knowles Roanne Govender Partner Partner Partner Partner Senior Immigration Consultant T: (09) 367 5919 T: (09) 367 5342 T: (09) 367 5892 T: (09) 367 5989 T: (09) 367 5841 E: [email protected] E: [email protected] E: [email protected] E: [email protected] E: [email protected]

Tax Transfer Pricing & Customs GST Indian Business Rebecca Armour Kim Jarrett Peter Scott Dinesh Naik Partner Partner Partner Partner T: (09) 367 5926 T: (09) 363 3532 T: (09) 367 5852 T: (09) 367 5867 E: [email protected] E: [email protected] E: [email protected] E: [email protected]

The information provided herein is of a general nature and is not intended to address the circumstances of any individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received nor that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. © 2017 KPMG, a New Zealand partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. KPMG and the KPMG logo are registered trademarks of KPMG International Cooperative (“KPMG International”), a Swiss entity.