Budget 2026 FIF changes

De minimis threshold: Increase the FIF cost threshold from NZ$50,000 to NZ$100,000 of overseas investments for the 2026-27 tax year, while still allowing investors to apply the FIF rules if they choose.

RAM for unlisted foreign shares: Allow all New Zealand tax residents to use the Revenue Account Method for unlisted foreign shares, so the method is no longer limited to recent migrants for those shares.

Extended RAM for concurrent-tax residents: Allow New Zealand residents who are concurrently taxed overseas because of citizenship or a right to work there to use extended RAM for listed and unlisted foreign shares.

AFI continuity for active investors: Allow founders, active investors, and key employees who previously held at least 10% and used the attributable FIF income method to continue using it after dilution below 10%, if they remain active and have the information needed.

Corporate migration exemption: Preserve the 10-year FIF exemption for qualifying New Zealand shareholders when a New Zealand business lists overseas, including listing paths such as SPAC transactions where share continuity is technically disrupted.

Threshold pages and tracker: The threshold tracker has separate settings for the current NZ$50,000 threshold and the proposed NZ$100,000 threshold for 2026-27.

Responsibility check: The guided check asks which income year you are checking, then changes the threshold, RAM, and active-investor prompts accordingly.

Calculator guidance: The FDR/CV calculator remains scoped to ordinary shares and ETFs, with 2026-27 proposal warnings where threshold assumptions may change whether FIF applies.

RAM content: The RAM guide separates current IR461 eligibility from the proposed expanded access for all residents with unlisted foreign shares and concurrent-tax residents with listed shares.

FAQ and filing checklist: The FAQ and filing checklist now include proposal-stage reminders for the threshold increase, expanded RAM, AFI continuity, and corporate-migration exemption.