Tax Risks and Compliance for Cross-Border Partnerships.
The course will address:
(a) The tax/compliance risks of New Zealand tax residents investing in partnerships/look-through entities established outside of New Zealand.(b) The tax/compliance risks of non-residents investing into limited partnerships formed in New Zealand.
Migration to New Zealand generally triggers a transitional tax residence exemption, which exempts foreign passive income from income tax in New Zealand for a period of 48/54 months. Migrants with look-through entities (e.g., US LLCs, German GmbH & Co KG) might be exposed to taxation from the day of arrival.
Foreign living wills or family partnerships (e.g., German GmbH & Co KG) are instruments that reduce tax exposure in the jurisdiction of establishment. However, these entities might trigger significant dividend taxation or general residence issues in New Zealand.
New Zealand Limited Partnerships with foreign limited partners will trigger a tax obligation in New Zealand. The offshore limited partners need to apply their domestic rules and the Double Tax Agreements when determining taxation on/offshore.
Suited to:
Tax Advisors, Lawyers, and Senior Accountants.
TEO Training provides practical learning experiences on primarily tax-related topics for accountants, lawyers and business advisors across New Zealand.
Principal at Peter Loerscher International Tax Limited
Peter Loerscher is the Principal of Peter Loerscher International Tax Limited and was previously (2005 to 2018) Inland Revenue’s Principal Advisor International Tax (SME). Peter is an accountant/tax specialist with a strong focus on international tax and is a well-known presenter.
