FIF rules
Foreign Investment Fund (FIF)
A New Zealand tax regime that applies to NZ-resident investors who hold most foreign shares or non-PIE foreign investment funds outside specific exemption thresholds.
The Foreign Investment Fund (FIF) rules are a NZ tax regime that taxes the *holding* of certain foreign shares and non-PIE funds, regardless of whether income is actually distributed. They were introduced to remove a tax preference for investing offshore.
NZ-resident individuals who hold less than NZ$50,000 of FIF-type investments at all times during the year are exempt — the de minimis threshold. Above the threshold, FIF income must be calculated under one of several methods (Fair Dividend Rate, Comparative Value, Cost or Deemed Rate of Return); Fair Dividend Rate is the default for shares.
Funds available to NZ retail investors that are *not* structured as NZ PIEs — for example, certain Australian Unit Trust versions of Vanguard funds — are subject to FIF rules for the NZ investor. ManagedFundsNZ flags these funds explicitly on each fund page.
PIE funds *internally* manage FIF tax on their underlying foreign holdings; the PIE investor does not personally apply FIF rules to their PIE units. This is one of the practical reasons PIEs are popular for retail offshore-equity exposure in NZ.
Common questions
- Do I have to file a FIF return?
- You only need to consider FIF if you hold non-PIE foreign investments above the NZ$50,000 de minimis threshold at any point during the year. Investments held inside NZ PIE funds do not count toward your personal FIF threshold.
- Is FIF the same as PIE?
- No — they are different tax regimes. PIE applies to investors in NZ PIE funds with tax capped at the PIR. FIF applies to NZ-resident individuals who personally hold foreign shares or non-PIE foreign funds above the de minimis threshold.
Primary sources
Related terms
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PIE fund · PIE
Portfolio Investment Entity (PIE)
A tax-efficient New Zealand fund structure where investor tax is capped at the investor's Prescribed Investor Rate (PIR), with a maximum of 28%.
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PIR
Prescribed Investor Rate (PIR)
The tax rate applied to your share of a PIE fund's taxable income. NZ has three PIRs: 10.5%, 17.5% and 28%. The maximum is 28%.