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CFC provisions in New Zealand (like everywhere that they exist) are designed to prevent a New Zealand resident individuals or entities from sheltering their income, profits or gains from the taxation of New Zealand by placing them in low-tax countries where they will be taxed lightly, if at all. To counter this, the CFC provisions impose a tax on the resident shareholders of the foreign company on the accrued profits made by Such companies, whether That profit is remitted to New Zealand or not. To overcome this, the provisions impose a tax on CFC resident shareholders of foreign companies on the benefits accrued are made by these companies, whether profits are sent to New Zealand or not. This is known as the attribution process. This is known as the attribution process. A parallel system of rules known as the Foreign Investment Fund (FIF) rules apply similar treatment to the interests of companies in investment funds. A parallel system of rules known as the Foreign Investment Fund (FIF) rules apply similar treatment to the company’s interest in investment funds.

Under New Zealand’s Controlled Foreign Company (CFC) and Foreign Investment Fund (FIF) rules, a New Zealand resident company or individual is taxed on its share of the underlying income of a foreign company or fund. The CFC and FIF rules do not apply to foreign companies or funds in the ‘gray list’ countries (Australia, Canada, Germany, Japan, Norway, Spain, the UK and the USA). In New Zealand Controlled Foreign Company (CFC) and Foreign Investment Fund (FIF) rules, New Zealand incorporated company or individual will be taxed on its share of underlying earnings of a foreign company or a fund performed. The CFC and FIF rules do not apply to foreign companies or funds in the ‘gray’ list of countries (Australia, Canada, Germany, Japan, Norway, Spain, Britain and the United States).

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