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NFI

Notified Foreign Investor (NFI)

A PIE-tax sub-regime for eligible non-resident investors. Foreign-sourced income inside the PIE is taxed at 0%; NZ-sourced income is taxed at the relevant non-resident withholding-tax rate.

The Notified Foreign Investor (NFI) regime allows non-resident investors in a NZ Portfolio Investment Entity to be taxed on a look-through basis. Foreign-sourced income that the PIE earns on behalf of the NFI is taxed at 0%; NZ-sourced income is taxed at the relevant non-resident withholding-tax rate (typically 15% on interest, 0–15% on imputed dividends).

A PIE must be specifically set up to support NFIs and the investor must complete an NFI declaration with the manager. If the PIE is not NFI-eligible, non-residents are taxed at the standard 28% non-resident PIE rate on all PIE income — typically less tax-efficient for offshore investors than NFI status.

NFI status is most relevant for migrants returning to NZ, Australians holding NZ PIEs, and managed-fund managers who distribute across borders. The OMI for each PIE-structured scheme usually states whether the scheme supports NFIs.

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