New Zealand and the UK signed a new income and capital tax treaty on 1 June 2026, replacing existing arrangements with a framework aimed at providing greater tax certainty for cross-border investment and incorporating OECD anti-abuse measures to address base erosion and profit shifting (BEPS).
New Zealand Inland Revenue has announced that a new income and capital tax treaty with the UK was signed on 1 June 2026.
The treaty applies to New Zealand income tax and to UK income tax, corporation tax and capital gains tax.
According to Inland Revenue, the new double taxation agreement (DTA) is intended to support cross-border trade and investment between New Zealand and the UK by providing greater certainty for taxpayers regarding their tax obligations while safeguarding New Zealand’s taxing rights.
The agreement also incorporates OECD-developed anti-abuse measures aimed at preventing base erosion and profit shifting (BEPS).
The treaty will enter into force once both countries have completed their respective domestic ratification procedures. In New Zealand, this will require the issuance of an Order in Council.
