Executive summary

The New Zealand Government enacted the Taxation (Annual Rates for 2024-25, Emergency Response, and Remedial Measures) Act 2025 (the Act) on 29 March 2025.

Key amendments contained in the Act include:

• Introducing standardized tax relief measures that can be switched on during emergency events
• Adopting the Organisation for Economic Co-operation and Development's (OECD's) crypto-asset reporting framework
• Addressing issues affecting the transfer to New Zealand of overseas pension and superannuation funds
• Allowing retrospective registration for the approved-issuer levy¹

Detailed discussion

The Act was first introduced as draft legislation on 26 August 2024. (For an overview of the key amendments as initially proposed in the draft legislation, see EY Global Tax Alert, New Zealand proposes generic emergency response tax relief measures and other changes, dated 4 September 2024.)

After undergoing some changes during the Parliamentary process, the draft legislation received Royal assent on 29 March 2025. The Act contains a wide array of changes, many of which are remedial in nature and are primarily aimed at clarifying the law and reducing compliance costs for taxpayers. Several of the key changes are outlined below.

Emergency response measures

From 1 April 2025, new standardized emergency response provisions can be switched on during an emergency event without the need to pass primary legislation. This change is aimed at allowing the New Zealand Inland Revenue Department (Inland Revenue) to provide timely relief for taxpayers in the event of an emergency.

Given the increasing incidence of emergency events, this change should ease pressure on Parliamentary schedules while providing greater certainty for taxpayers in times of crisis.

Crypto-asset reporting framework

The Act adopts the OECD's Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard (CARF) in New Zealand. CARF is aimed at increasing transparency around crypto-asset ownership by providing for the collection and automatic exchange of information on crypto assets. The changes include new information collection and reporting obligations for New Zealand-based reporting crypto-asset service providers from 1 April 2026.

New Zealand's adoption of these rules is perhaps unsurprising, particularly given Inland Revenue's increased focus on crypto assets.²

Transfer of overseas pension funds

Changes are made to address issues affecting the transfer of overseas pension and superannuation funds to New Zealand. In particular, from 1 April 2025 certain currently "locked-in" funds originally transferred from the United Kingdom (UK) to a New Zealand KiwiSaver³ scheme can be transferred to a New Zealand qualifying recognized overseas pension scheme (QROPS). This change is intended to allow for the balance of the person's funds in the KiwiSaver scheme to be managed without UK tax implications.

Approved-issuer levy

From 1 April 2025, it is now possible to seek retrospective registration of securities for the 2% approved issuer levy (AIL) instead of Non-Resident Withholding Tax in certain circumstances. This amendment will be welcome news for affected taxpayers.

Other reforms

The Act includes several other reforms, including:

• Remedial amendments for limited partnerships, including allowing nonresident partners to access AIL in some cases
• Numerous remedial goods and services tax (GST) changes, many of which are aimed at easing compliance costs for taxpayers
• Clarification of aspects of the Portfolio Investment Entity (PIE) eligibility criteria

Preparing for compliance

Now that the changes are enacted, Inland Revenue will begin establishing the necessary administrative processes to facilitate compliance. This will include the publication of Inland Revenue guidance to help taxpayers understand the key changes.