2026–27 FIF Bill changes

De minimis threshold: Increase the total-cost de minimis threshold for attributing FIF interests from NZ$50,000 to NZ$100,000 from 1 April 2026, while still allowing eligible investors to apply the FIF rules if they choose. The four-year look-back would test each earlier year against the threshold that applied in that year.

RAM for unlisted foreign shares: Allow New Zealand-resident natural persons and eligible trustees to use the Revenue Account Method for qualifying unlisted foreign shares, irrespective of when they arrived in New Zealand.

Extended RAM for concurrent-tax residents: Allow New Zealand-resident natural persons and eligible trustees who face concurrent taxation 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 qualifying active investors whose stake falls below 10% to continue using attributable FIF income. This can include people who used AFI previously or would have been eligible before an exemption or residency transition, provided the detailed active-role and information requirements continue to be met.

Corporate reorganisation exemption: Preserve the 10-year FIF exemption for qualifying New Zealand shareholders through overseas listings and reorganisations such as SPAC transactions, share-for-share exchanges, amalgamations, mergers, and liquidations.

RAM exit tax for treaty non-residents: From 1 April 2027, extend the RAM deemed-disposal and suspended-liability rules to a person who remains New Zealand resident under domestic law but is treated as non-resident under a double tax agreement.

Indirect FIF interests held through a CFC: Allow a holder with an indirect attributing interest through a controlled foreign company to choose methods available as if the FIF interest were held directly, potentially including CV or RAM. The commentary states this would apply to the 2025-26 and later income years with effect from 1 April 2026.

Cost method alongside FDR or CV: Allow cost method for FIF interests without a readily available market value while retaining the portfolio choice of FDR or CV for readily valued interests from 2026-27.

Threshold pages and tracker: The tracker has separate settings for the current NZ$50,000 threshold and the Bill's proposed NZ$100,000 threshold, plus a warning that the four-year look-back can still affect eligibility.

Responsibility check: The guided check asks which income year you are checking, then changes the threshold, RAM, and active-investor prompts while keeping specialist cases outside the automated result.

Calculator guidance: The FDR/CV calculator remains scoped to ordinary shares and ETFs. It does not decide RAM, AFI, indirect-CFC, cost-method, or treaty-residence questions.

RAM content: The RAM guide separates enacted IR461 rules from the Bill proposals, including the proposed five-year consistency rule and treaty tie-break exit treatment.

FAQ and filing checklist: The FAQ and checklist flag the Bill-stage threshold, RAM, AFI, corporate-reorganisation, indirect-interest, and mixed-method proposals.