The amending protocol to the 2006 income and capital tax treaty between Austria and New Zealand was enacted on 29 August 2024. Signed on 12 September 2023, this protocol represents the first amendment to the treaty.
The main changes are as follows:
Paragraph 2 of Article 10 (Dividends) is replaced, establishing the following withholding tax rates:
- 5% if the beneficial owner is a company that directly holds, in the case of Austria, at least 10% of the capital of the paying company, and in the case of New Zealand, at least 10% of the voting power in the paying company throughout a 365-day period that includes the day of the payment of the dividend;
- For other cases, the rate is 15%.
The protocol takes effect for withholding taxes starting on 1 October 2024. For other taxes, it applies in Austria from 1 January 2025 and New Zealand from 1 April 2025.
