Controlled Foreign Company (CFC) and Foreign Investment Fund (FIF)
CFC
A CFC is a foreign company that is more than 40% controlled by one New Zealand resident or more than 50% controlled by two to five New Zealand residents. Income is taxable in New Zealand if the CFC’s "passive income" is equal to or more than 5% of the total income earned by the CFC.
Non-portfolio FIF
This is a foreign company owned 10% or more (but not controlled) by New Zealand residents. Taxed either as a CFC or as a portfolio FIF.
Portfolio FIF
A foreign company not controlled by New Zealand residents, or a foreign superannuation scheme or foreign life insurance policy. An ownership interest of less than 10% is required. Taxed using one of six methods:
- Fair dividend rate (FDR)
- Cost
- Comparative value (CV)
- Deemed rate of return (DRR)
- Attributable FIF income method
- Revenue Account Method (RAM)
A foreign superannuation scheme entered into by a non-resident is subject to separate rules when lump sum withdrawals are made from the scheme. Regular pensions and commutation payments are taxed as income.