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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