Revised FIF rules edged closer to enactment with the passing of the Taxation (Annual Rates for 2025–26, Compliance Simplification, and Remedial Measures) Bill on 26 August 2025 – Part Two: Revenue Account Method (‘RAM’)

by Gina Gatchell | Sep 28, 2025 | Articles

Introduction and Scope

Part One of this series detailed how the proposed changes to N.Z.’s FIF rules[1] may affect N.Z. tax residents who are subject to tax of another country, notably the U.S., through citizenship, or lawful permanent residence[2].

Those individuals may elect the ‘extended RAM’ as explained in Part One.

The provisions discussed in this article will apply to the category of taxpayers who aren’t subject to tax in another country through citizenship, or lawful permanent residence of another country.

This category of taxpayers represents the greater population of N.Z. tax residents with interests in foreign companies. This is since all countries, except the United States and Eritrea, impose individual income tax on a residency basis. Thus, individuals from all other countries do not have ongoing tax obligations to any country based on residence, only income sourced from that country.

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