Share with your friends

New Zealand - Special considerations for short-term assignments

Special considerations for short-term assignments

Taxation of international executives


Related content

Residency rules

Are there special residency considerations for short-term assignments?

Residence for short term assignees will be determined on the same basis as for other assignees. The residence tests were discussed earlier.

Where a secondment is for a short period (less than 92 days in total during the income year) then remuneration derived by a non-resident will generally be exempt from New Zealand tax, provided that the income is taxable in the home country/jurisdiction and the employer is not resident in New Zealand.

Relief from New Zealand taxation may also be provided under international double tax agreements to which New Zealand is a party. Such treaties generally exempt from New Zealand tax remuneration derived by a person who is present in New Zealand for less than 183 days during any 12-month period, provided that income is paid by an employer who is not a New Zealand resident or does not have a permanent establishment in New Zealand.

Payroll considerations

Are there special payroll considerations for short-term assignments?

Withholding tax obligations in New Zealand would need to be considered. If an assignee carried work out in New Zealand, this will be sourced in New Zealand even if paid overseas.

If the taxpayer cannot determine that income is exempt under the 92-day rule or double tax agreement, then the employer may pay a bond to the Inland Revenue Department equal to the amount of tax deductions that would have been deducted.

Taxable income

What income will be taxed during short-term assignments?

If a short-term assignee is in New Zealand for more than 183 days, the assignee is taxable as resident on worldwide income basis, unless they meet the transitional resident rules (see previous). In contrast, a non-resident is taxable only on New Zealand sourced income.

Additional considerations

Are there any additional considerations that should be considered before initiating a short-term assignment in New Zealand?

Whether there is a risk that the assignment will create a Permanent Establishment for the overseas employer.


All information contained in this publication is summarized by KPMG New Zealand, the New Zealand member firm affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based the Income Tax Act 2007, Estate and Gift Duties Act 1968..

© 2021 KPMG, a New Zealand partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved.

KPMG International Cooperative (“KPMG International”) is a Swiss entity.  Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

Connect with us


Want to do business with KPMG?


loading image Request for proposal

Stay up to date with what matters to you

Gain access to personalized content based on your interests by signing up today

Sign up today