NEW ZEALAND Law and Practice Contributed by: Greg Neill, Fred Ward and Callum Burnett, Russell McVeagh
the value of these supplies exceeds (or is expected to exceed) NZD60,000 in a 12-month period. Such sup - pliers are also not required to return GST on supplies made to New Zealand GST-registered businesses. 9.13 Approach to Digital Services Taxation As noted in 9.2 Government Policy and Objectives Approach , New Zealand introduced a Bill in August 2023 providing for a comprehensive DST in New Zea - land (as an alternative to Amount A under Pillar One). However, in May 2025, the government announced that it had decided not to proceed with the proposed DST and the Bill was subsequently formally aban - doned. There have not been any announced policies or proposals to address digital taxation since that decision was made. 9.14 Offshore IP Provisions New Zealand has not introduced any transfer provi - sions dealing specifically with the taxation of offshore- based intellectual property. It is legislatively prescribed in New Zealand’s transfer pricing rules that those rules are to be applied consistently with the OECD’s Trans - fer Pricing Guidelines for Multinational Enterprises and Tax Administrations (July 2022 edition). In that sense, the guidance on intangible assets and supply arrangements contained in Chapter VI of the OECD Transfer Pricing Guidelines is incorporated into New Zealand law.
The payment of royalties by New Zealand residents for the use of offshore-owned intellectual property is a current focus of Inland Revenue. Licensing arrange - ments with offshore-based related parties or associ - ates present a risk to the New Zealand tax base if outbound payments are not priced in accordance with the arm’s length principle. The transfer of intellectual property out of New Zealand is also a focus of Inland Revenue, particularly where an intellectual property asset is sold and then licensed back to the original owner.
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