New Zealand

A. Progress in the implementation of the minimum standard

New Zealand has 40 tax agreements in force, as reported in its response to the Peer Review questionnaire. Sixteen of those agreements, the agreements with Australia, Belgium, Canada, China, Denmark, Finland, France, India, Ireland, Japan, the Netherlands, Poland, Samoa*, Singapore, the United Arab Emirates and the United Kingdom, comply with the minimum standard.

New Zealand signed the MLI in 2017 and deposited its instrument of ratification on the 27 June 2018. The MLI entered into force for New Zealand on 1 October 2018.

New Zealand indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used for its agreements with Austria, the Slovak Republic and Switzerland.

New Zealand is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

B. Implementation issues

No jurisdiction has raised any concerns about their agreements with New Zealand.

Summary of the jurisdiction response – New Zealand

Treaty partners

Compliance

with the

standard

If compliant,

the alternative

implemented

Signature of

a complying

instrument

The alternative

implemented through the

complying instrument

(if not the MLI)

Comments

1

Australia

Yes

PPT alone

N/A

N/A

2

Austria

No

N/A

Yes

N/A

3

Belgium

Yes

PPT alone

N/A

N/A

4

Canada

Yes

PPT alone

N/A

N/A

5

Chile

No

N/A

Yes

N/A

6

China (People's Republic of)

Yes

PPT alone

N/A

N/A

2019 China-NZ treaty contains preamble and PPT article.

7

Chinese Taipei*

No

N/A

No

N/A

8

Czech Republic

No

N/A

Yes

N/A

9

Denmark

Yes

PPT alone

N/A

N/A

10

Fiji*

No

N/A

Yes

N/A

11

Finland

Yes

PPT alone

N/A

N/A

12

France

Yes

PPT alone

N/A

N/A

13

Germany

No

N/A

Yes

N/A

14

Hong Kong (China)

No

N/A

Yes

N/A

15

India

Yes

PPT alone

N/A

N/A

16

Indonesia

No

N/A

Yes

N/A

17

Ireland

Yes

PPT alone

N/A

N/A

18

Italy

No

N/A

Yes

N/A

19

Japan

Yes

PPT and LOB

N/A

N/A

The treaty already contained an LOB and this is unaffected by the MLI

20

Korea

No

N/A

Yes

N/A

21

Malaysia

No

N/A

Yes

N/A

22

Mexico

No

N/A

Yes

N/A

23

Netherlands

Yes

PPT alone

N/A

N/A

24

Norway

No

N/A

Yes

N/A

25

Papua New Guinea

No

N/A

Yes

N/A

26

Philippines*

No

N/A

Yes

N/A

27

Poland

Yes

PPT alone

N/A

N/A

28

Russia

No

N/A

Yes

N/A

29

Samoa*

Yes

PPT alone

N/A

N/A

30

Singapore

Yes

PPT alone

N/A

N/A

31

South Africa

No

N/A

Yes

N/A

32

Spain

No

N/A

Yes

N/A

33

Sweden

No

N/A

Yes

N/A

34

Switzerland

No

N/A

Yes

N/A

35

Thailand

No

N/A

Yes

N/A

36

Turkey

No

N/A

Yes

N/A

37

United Arab Emirates

Yes

PPT alone

N/A

N/A

38

United Kingdom

Yes

PPT alone

N/A

N/A

39

United States

No

N/A

No

N/A

Contains an LOB as per US treaty policy

40

Viet Nam

No

N/A

Yes

N/A

Note

← 1. For its agreements listed under the MLI, New Zealand is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).

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