New Zealand Trust

Specialist jurisdiction

Offshore Companies · New Zealand Trust

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Asia Pacific New Zealand
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Written and reviewed by John Evans Connor Steens
Updated

Statute

Trusts Act 2019

Trustee

A minimum of one New Zealand-resident trustee

Registration

The foreign-source exemption depends on IRD registration

Annual compliance

Annual return and financial statements

Duration

Maximum term of 125 years

Tax basis

Treatment is settlor-based; qualifying foreign-source income may be exempt

This is a general summary only. Whether you qualify, and how tax and reporting apply, turns on the settlor, the beneficiaries, the assets, the trustee arrangements and each home jurisdiction that is relevant.

Standalone

New Zealand Foreign Trust

On application

Scope confirmed after trustee review

A standalone trust under New Zealand law, run by a New Zealand-resident trustee and registered with Inland Revenue.

Coordination of professional trustee onboarding and due diligence
Trust deed and formation paperwork compliant with New Zealand law
IRD registration together with first-year compliance scope
Discuss this option
Trust + company

Trust sitting above an underlying New Zealand company

On application

Scope confirmed after trustee review

The trust holds a New Zealand company able to hold approved bank, brokerage, investment or operating assets.

New Zealand Foreign Trust formation
Underlying New Zealand company
Ownership documents for the trust and company prepared in a coordinated way
Discuss this option
01 · Settlor

Non-New Zealand settlor

The structure is meant for a settlor who has not been New Zealand tax resident. Should the settlor's residence later change, specialist advice must be sought at once.

02 · Trustee

New Zealand-resident trustee

The trust is administered by at least one New Zealand-resident trustee, who holds legal title to the trust property and is bound to follow the trust deed and statutory duties.

03 · Registration

IRD registration

Registration of the foreign trust with Inland Revenue is required, and the trustee has to keep the information called for under the foreign-trust disclosure regime.

04 · Tax

Foreign-source exemption

Qualifying foreign-sourced income may escape New Zealand income tax. That exemption does not reach New Zealand-source income or home-country tax rules.

05 · Reporting

Annual returns and records

Inland Revenue may need to be supplied with annual returns, financial statements and details of relevant settlements, distributions and connected persons.

06 · Governance

Professional administration

The trust has to be run genuinely as a trust. Trustee decisions, records, asset ownership and beneficiary information ought to stay current and be properly documented.

Important: a New Zealand Foreign Trust is transparent to the relevant tax and law-enforcement authorities and does not replace home-country legal or tax advice.

Jurisdiction fit before formation

Before recommending it, we measure New Zealand against purpose-built trust jurisdictions, so institutional credibility is never mistaken for adversarial asset protection.

Professional trustee coordination

We manage the application, due diligence, deed drafting and registration steps with well-established New Zealand professional trustee providers.

Pricing confirmed on application

Formation scope and fees are laid out before work begins, and trustee charges, third-party costs and continuing administration are explained through onboarding.

Company and banking support

When a trust also calls for an underlying company, banking, brokerage or another jurisdiction, we can arrange the wider structure through a single point of contact.

Compliance-aware implementation

Where needed, optional legal and tax coordination can be layered on so the structure is weighed alongside the client's home-country reporting and compliance duties.

A strong fit for

Credibility-led international planning

New Zealand is at its most attractive when a client places value on a well-regarded OECD jurisdiction, English common law and professional administration.

Internationally mobile entrepreneurs and Asia-Pacific families
Holding foreign investments behind a clean institutional profile
Family governance, estate planning and succession
Clients at ease with IRD registration and information exchange
Important limitations

Not a purpose-built protection jurisdiction

New Zealand delivers standard trust-law separation, yet it does not reproduce the specialist creditor defences linked to Cook Islands or Nevis trusts.

No fixed statutory creditor limitation period and no compulsory creditor bond
Trust details are not public, though relevant information is reported to Inland Revenue
Transfers made to defeat creditors can be challenged
Relocating to New Zealand in future can significantly alter the tax position
We should put New Zealand forward only where its credibility, tax framework and administration truly line up with the client's objectives.
total protection package
  • The New Zealand trustee application handled end to end
  • Trustee, registration and third-party charges broken out in the written quote
  • A trust deed compliant with New Zealand law drafted alongside supporting ownership documents
  • The structure registered and ready to take in trustee-approved assets

Founder & Chief Executive Officer

Rarotonga, Cook Islands

More than two decades of experience across offshore banking, asset protection, international companies and trusts.

Connor Steens
BBUS

Founder & Business Development Director

Sydney, Australia

Specialises in offshore structuring, strategic partnerships, business development and global wealth solutions.

Atinata Hosking

Sales Manager

Rarotonga, Cook Islands

Brings more than two decades of experience in offshore banking, regulatory compliance and client relationship management.

Melanie Tetuaiteroi

Sales Assistant

Rarotonga, Cook Islands

Supports client onboarding, communications, documentation and operational coordination, backed by fiduciary administration experience.

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A New Zealand Foreign Trust operates under New Zealand law with at least one New Zealand-resident trustee, while the settlor has not been New Zealand tax resident. It is typically put to legitimate use for international investment holding, succession and estate planning.

We quote pricing on application. The figure hinges on the professional trustee, how complex the deed is, the assets proposed, the yearly compliance scope and whether a New Zealand company or banking support forms part of it.

Qualifying foreign-sourced income may be exempt where the foreign-trust conditions and disclosure requirements are satisfied. New Zealand-source income, along with the home-country obligations of the settlor or beneficiaries, stays subject to the applicable tax rules.

Yes. To keep access to the foreign-source income exemption, the New Zealand-resident contact trustee has to register the foreign trust and meet the continuing disclosure and annual-return requirements.

The foreign-trust register is not open to the public. Inland Revenue does, however, receive information on the trust and may pass reportable details to relevant New Zealand agencies and overseas tax authorities under the applicable exchange arrangements.

It gives the ordinary legal separation of a trust that is properly set up and independently administered. New Zealand is not a jurisdiction purpose-built for adversarial asset protection and lacks the fixed claim periods, creditor bonds or specialist statutory defences that some offshore trust jurisdictions provide.

Under the Trusts Act 2019 the maximum duration is generally 125 years, though a shorter term can be set in the trust deed.

The tax classification and treatment could shift significantly. Anyone with a possible move to New Zealand should get specialist New Zealand tax advice before formation and once more ahead of any residency change.

Yes, provided the trustee accepts and the provider's due diligence is satisfied. An underlying company can hold approved bank, brokerage, investment or operating assets, while opening the account still depends on the institution's own independent approval.

Generally not where aggressive or adversarial creditor protection is the main goal. In that case, we should weigh purpose-built jurisdictions such as the Cook Islands or Nevis before putting New Zealand forward.