Trusts – Cross Border Taxation Issues 2019


This webinar considers cross-border taxation issues for trusts in the light of Inland Revenue’s interpretation statement on the taxation of trusts and pending legislative reforms.

Some of the key issues arising from the interpretation statement which will be addressed include the tax treatment of “dual status trusts” (i.e. trusts that are both “foreign trusts” and “complying trusts”) and the tax treatment of distributions from “non-complying trusts” and “foreign trusts”.

Other cross border tax issues which will be considered include retaining “complying trust” status when settlors cease to be New Zealand tax resident, obtaining “complying trust” status when settlors become New Zealand tax resident, the effect of changes in tax residence status of trustees and beneficiaries, and the impact of the transitional residence rules.

The special rules that apply to “foreign trusts” with a New Zealand-resident trustee will also be discussed. These include the requirement for New Zealand foreign trusts to register with Inland Revenue, file annual returns and pay registration and filing fees.


You will:

  • Know the difference between “complying trusts”, “foreign trusts”, “non-complying trusts” and “dual status trusts”
  • Understand how distributions from different types of trusts are taxed, including distributions from “dual status trusts”
  • Learn how a trust can retain its “complying trust” status when a settlor ceases to be New Zealand tax resident
  • Know how a “foreign trust” can become a “complying trust” when a settlor becomes New Zealand tax resident
  • Understand what tax implications can arise where trustees and beneficiaries change their tax residence status
  • Learn how the transitional residence rules interface with the rules for taxing trusts
  • Understand the registration and disclosure rules for “foreign trusts” and “dual status trusts” with a New Zealand tax resident trustee, and the consequences if these rules are not complied with


Intermediate and senior accountants, tax lawyers, trust lawyers and others who act as trustee of clients’ trusts.


Stephen Tomlinson, Principal, Tomlinson Law

1.5 CPD Hours

  • Oct 17
    Thu, 2:30 PM NZDT - 4:00 PM NZDT Online
    • $210.00 excl. GST

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