FIF Basics
Start here if you are unsure what FIF means or whether overseas shares, ETFs, or managed investments need special tax treatment in New Zealand.
Check whether FIF may apply
Use the guided check before moving into calculations.
Check the FIF cost threshold
Track cost, reinvestments, and ownership share before calculating FIF income.
What is FIF tax?
FIF stands for Foreign Investment Fund. The FIF rules decide how some overseas investments, such as foreign shares and ETFs, are taxed in New Zealand.
If you're a New Zealand tax resident and you hold overseas investments, some of those investments may be "attributing interests". When they are, the FIF rules tell you how to calculate the income to include in your tax return.
FIF is not usually a separate tax bill. It is a set of calculation rules. Sometimes those rules can produce taxable income even if you did not receive cash dividends or sell the investment during the year.
Why does New Zealand have FIF rules?
The broad idea is to reduce the tax advantage that can arise from holding portfolio investments overseas instead of through New Zealand investment vehicles such as PIE funds.
Without FIF rules, some investors could defer or avoid New Zealand tax on offshore investments in ways that are not available for many local funds. FIF rules bring those investments into the New Zealand tax system using set calculation methods.
Who Needs to Consider FIF?
NZ Tax Residents
IR461 says the FIF rules apply to New Zealand tax residents who are not transitional residents and who hold attributing interests in overseas investments. This can include individuals, trusts, and companies.
Common exclusions
Transitional Residents
IR461 defines a transitional resident as a natural person who is a New Zealand tax resident, has not previously been a transitional resident, has been non-resident for 10 years or more, and has not applied for Working for Families Tax Credits. Transitional residents are outside the FIF calculation flow while the exemption applies.
The year the exemption ends needs separate care. The FIF starting value may be the market value on the day after transitional residency ends, not the value at 1 April. Read the guide for the year your exemption ends →
Residency timing: IR461 includes the Revenue Account Method (RAM) from 1 April 2025 for eligible individuals and family trusts. Budget 2026 proposes wider RAM access from 2026-27. RAM can provide an alternative calculation method for qualifying FIF interests, with gains and losses on disposal reduced by 30% before marginal tax is applied. Learn more about RAM →
Small Investments (FIF Cost Threshold)
If you are a natural person or eligible trustee (type A) and the total cost of all your attributing FIF interests stays at or below the relevant threshold throughout the entire income year, you generally do not need to calculate FIF income unless you opt in. Current IR461 guidance uses NZ$50,000; Budget 2026 proposes NZ$100,000 from 2026-27. Other tax rules may still apply. We cover this threshold in detail in the Thresholds & Exemptions section →
What investments are usually covered?
If exemptions don't apply, the FIF rules commonly cover investments like:
Shares in foreign companies: Direct holdings in companies that are not resident in New Zealand, such as Nvidia (NVDA), Apple (AAPL), Microsoft (MSFT), or Tesla (TSLA) on US exchanges.
Foreign unit trusts and ETFs: This includes many overseas-listed ETFs, such as VOO, VTI, and QQQ, because they are often structured as foreign companies or unit trusts.
Certain foreign superannuation schemes: Interests in some non-New Zealand retirement schemes, depending on when and how you acquired them. Withdrawals from many foreign schemes have their own tax rules.
Certain foreign life insurance policies: Policies offered or entered into outside New Zealand where the insurer is a FIF.
What investments are usually outside FIF?
The FIF rules generally don't apply to:
Most ASX-listed Australian shares: Shares in Australian-resident companies listed on the ASX that meet specific criteria, including maintaining a franking account, are usually exempt. Learn more about the ASX exemption →
Directly owned overseas rental property: Rental income from overseas property is dealt with under different tax rules.
Foreign bank accounts and term deposits: These are typically handled under the financial arrangements rules, not FIF.
Controlled Foreign Companies (CFCs): IR461 says a FIF does not include an income interest of 10% or more in a controlled foreign company. In general, a CFC is a company where five or fewer New Zealand residents hold more than 50% of the control interests, or one New Zealand resident holds 40% or more.
Being a beneficiary of most foreign trusts: Simply being a beneficiary does not usually trigger FIF, though distributions you receive may be taxable.
Loans: Making a loan to a foreign entity.
Important: This is general guidance. FIF treatment depends on your own facts, so check Inland Revenue guidance or speak with a qualified tax professional before filing.