Tax Policy Bulletin

September tax Bill has been released

The latest tax bill, Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill (the Bill) was introduced to Parliament on 10 September 2026, alongside commentary from Inland Revenue. The Bill provides legislative design around several Budget 2026 items and brings together a broad package of simplification, integrity and remedial changes across the tax system. The Bill is significantly larger than other recent annual rates bills, and covers a breadth of tax matters.

Key measures, among many others, include:

A new category-based approach to motor vehicle FBT replacing the current day-counting and exemption framework with six vehicle-use categories
Broader access to the FIF revenue account method, together with a FIF de minimis threshold increase from $50,000 to $100,000
New elective functional currency regime to reduce the impact of NZD exchange-rate movements, alongside a new cash-basis regime aimed at reducing double taxation for certain overseas-taxed individuals
In-year RDTI payments, expands eligible mining R&D expenditure, reduces the internal software development expenditure cap from $25 million to $3 million
A simplified non-resident contractors’ tax regime, including a $75,000 exemption threshold and single-payer basis
Changes for charities and not-for-profits, including an increase in the statutory deduction from $1,000 to $10,000 and filing relief for smaller organisations
Amendments to the application of the transitional under-taxed profits rule safe harbour for certain multinational enterprises, and to simplify GloBE filing requirements, including where no top-up tax liability arises and by allowing a single multinational top-up tax return to be filed on behalf of relevant group entities

The Bill also contains several non-Budget measures, including new rules for cryptoasset lending and stablecoins, GST pre-registration costs and error corrections, approved issuer levy changes, alignment of transitional residence with DTA residence, and a range of business and technical remedials.

For more tax policy information on the Bill, see the following:

We are currently preparing our Tax Tips publication covering the key amendments in the Bill and what they mean for taxpayers. Please watch this space for more.

PwC publications

PwC has recently published a Tax Tips summarising the key tax policies announced by the major political parties ahead of the 2026 election, highlighting the key differences and what they could mean for taxpayers and businesses. Please see our latest Tax Tips for more.

Other recent announcements:

Approval for Approved Information Sharing Agreement between Inland Revenue and Customs Information release.
- This information release includes documents relating to the Approval for Approved Information Sharing Agreement between Inland Revenue and Customs. Published 27 August 2026.
DET 26/06 Tax Administration (Fringe Benefit Tax, Interest on Loans) Determination 2026.
- For the quarter commencing 1 October 2026 and subsequent quarters, the fringe benefit tax prescribed rate of interest that is to apply to employment-related loans is 6.07%. Published 26 August 2026.
TDS 26/12 Property as trading stock.
- This item summarises a private ruling about whether a building and fit-out are trading stock for Investment Boost purposes. Published 28 August 2026.
TIB Volume 38 No 8 Tax Information Bulletin - September 2026.
- The Tax Information Bulletin is a monthly publication which contains information about changes to tax-related legislation, proposed legislation, judgments, rulings and other specialist tax topics including many of the publication types. Published 1 September 2026.
TDS 26/13 Derivation of holiday pay remedial payments and calculation of terminal tax.
- This item summarises an adjudication that considered the validity of a taxpayer’s Notice of Proposed Adjustment (NOPA), a PAYE deduction from a remedial payment of holiday pay and the allocation of income and terminal tax for the remedial payment. Published 10 September 2026.
Budget 2026 Information release.
- This information release includes documents relating to Budget 2026. Published 10 September 2026.

Open consultations

PUB00548 Can an Active Investor Plus visa holder become tax resident under the permanent place of abode test?
- There have been some questions and uncertainty raised around the potential for Active Investor Plus visa holders to trigger New Zealand tax residence. We have been asked, in particular, whether an Active Investor Plus visa holder buying a residential property in New Zealand and staying there when in New Zealand during the investment period (and beyond) may result in the person having a permanent place of abode in New Zealand and so being tax resident here. This “question we’ve been asked” (QWBA) provides guidance on how the Commissioner sees the permanent place of abode test applying in various AIP visa scenarios. Consultation closes 13 October 2026.
PUB00266 Income Tax – Non-resident software suppliers’ payments derived from New Zealand
- This interpretation guideline addresses payments made by New Zealand entities to non-residents in connection with software transactions. Its focus is on explaining the principles behind the classification of common types of software transactions. It also outlines the relevant income tax implications of those transactions under New Zealand law, including the impact of double tax agreements (DTAs). Consultation closes 31 October 2026.

Recently closed consultations

PUB00504 Income Tax cash incentives for banking customers
- This question we’ve been asked explains the income tax treatment of a cash incentive payment (also known as a cashback payment) that a bank pays to a borrower who is a cash basis person under the financial arrangements rules. It explains when a cash incentive payment will not be taxable and will not give rise to any tax obligations for the borrower who receives it. It also explains when a cash incentive payment will be taxable and the time at which it must be accounted for when it is. Consultation closed 3 September 2026.

For more information about upcoming consultations please see here for Tax Technical and here for Tax Policy.