Working from New Zealand as a France resident

At a glance

Rule coverage

What the rules say about New Zealand

The rules below are the ones most likely to shape a stay in New Zealand, in plain words and with the source behind each one. Your own report tells you which of them apply to you.

1. Significant issuePermanent establishment risk

   Incorporating in New Zealand does not stop your company being a Dutch taxpayer too, if you keep running it from a Dutch kitchen table

   New Zealand's own company residence test, confirmed via PwC's corporate residence summary, treats a company as New Zealand tax resident if ANY ONE of four things is true, it is incorporated in New Zealand, its head office is in New Zealand, its centre of management is in New Zealand, or its directors exercise control from New Zealand. Crucially, incorporation alone is enough, meaning a New Zealand-incorporated company stays New Zealand resident regardless of where it is actually run from. The trap is what this does NOT prevent, if the real decision-making, the centre of management, actually happens from a home office in the Netherlands, that same company is very likely also a Dutch tax resident under the Netherlands' own management-and-control test, creating a genuinely dual-resident company. The 1980 Netherlands treaty, as amended by the 2001 protocol, has a tie-breaker mechanism for this, but this research could not retrieve the current Article 4 company tie-breaker text to state confidently which country would win, or on what basis, for a specific case.

2. Significant issuePersonal income tax

   Foreign share portfolios over NZD 50,000 cost get taxed on a notional return, not on what they actually paid you, and this is the most commonly missed rule in this corridor

   The foreign investment fund (FIF) rules are New Zealand's most consequential trap for a Dutch person who keeps a foreign brokerage or investment account after becoming tax resident, confirmed directly on Inland Revenue's own FIF pages. If your attributing interests in foreign companies, foreign unit trusts, foreign superannuation schemes or foreign life insurance policies cost NZD 50,000 or more in total, you generally have to calculate FIF income every year using one of several methods (fair dividend rate, comparative value, cost, deemed rate of return, revenue account method, or attributable FIF income), most of which tax you on a notional percentage return regardless of whether the investment actually paid you anything or even lost value that year. Below NZD 50,000 total cost, you are exempt from the calculation entirely. A narrower exemption also applies to ASX-listed Australian shares held in companies that meet specific franking conditions.

3. Significant issueCrypto tax and legal status

   Inland Revenue treats crypto as property, every disposal, including swapping one coin for another, is taxed as ordinary income at up to 39 percent

   This is one of the genuine nasty surprises in this corridor. Inland Revenue treats cryptoassets as a form of property, confirmed directly on its own cryptoassets guidance pages, and taxes the profit on disposal (sale price minus cost) as ordinary income at your marginal rate, up to 39 percent, with no capital gains tax shelter, no lower long-term rate, nothing like it. Critically, swapping one cryptocurrency for another counts as a taxable disposal, you do not need to convert to NZD first for a tax event to occur. There is a narrow argument that a genuinely long-term, non-sale holding purpose (pure store of value, never intended for resale) might be non-taxable, but Inland Revenue sets a high bar for that argument and it should not be assumed.

4. Needs checkingMoving your company

   Every New Zealand company needs at least one director who actually lives in New Zealand, or in Australia while also directing an Australian company

   Confirmed directly on the Companies Register's own guidance, section 10 of the Companies Act 1993 requires every New Zealand company to have at least one director who lives in New Zealand, or who lives in Australia and is also a director of a body corporate incorporated there, Australia being the only country New Zealand currently treats this way. The Registrar generally treats someone as living in New Zealand if they have been physically present for more than 183 days in a 12-month period, though the Registrar can accept other evidence of genuinely living there even below that threshold on a case-by-case basis. A solo Dutch founder incorporating remotely, with no New Zealand or Australian presence, cannot satisfy this alone.

5. Needs checkingTax residency

   Spend more than 183 days in New Zealand in any 12-month period and you become tax resident from day one of that count

   Confirmed directly on Inland Revenue's own tax residency page, you become a New Zealand tax resident once you have been personally present for more than 183 days in total within any 12-month period. Part days, including your arrival and departure days, count as whole days, and the days do not need to be consecutive. The important sting is that your residency backdates to the first of those 183 days, not the day you crossed the threshold, so a chunk of income earned before you realised you had tipped over can already be taxable as a New Zealand resident.

6. Needs checkingHealthcare coverage

   Public healthcare is not automatic, you need a work visa valid for 2 years or more, residence, or citizenship to qualify

   Confirmed directly via the Ministry of Health's own eligibility guidance, most temporary visa holders, including short-term visitors and many work visa holders, cannot access publicly funded healthcare in New Zealand at all. The main route in on a work visa is holding one that entitles you to remain in New Zealand for 2 years or more from your first day, or that combined with time you have already lawfully spent in New Zealand adds up to 2 years or more. Below that, you are generally expected to rely on private travel or health insurance for anything beyond ACC-covered accidental injury, which is a completely separate system covered in its own finding.

Tax treaty between France and New Zealand