TreatyIndia–NZ DTAA
RiskPE & tax residence
PaymentsForm 15CA/CB
OutboundFEMA ODI
NZ desk · India–NZ
An NZ company is an NZ taxpayer. Indian residents who own it, work for it, or receive dividends still have Indian tax and FEMA work to do. A Companies Office number does not make the income tax-free in India.
What this file usually covers
- India–New Zealand Double Taxation Avoidance Agreement — dividends, interest, royalties, and business profits follow treaty articles and beneficial-ownership tests.
- Permanent establishment risk if the NZ company is managed from India or has a dependent agent in India.
- Form 15CA/CB and withholding when an Indian company pays the NZ entity for services, royalties, or interest.
- FEMA outbound investment when Indian residents subscribe to NZ share capital or send share-application money.
- NRI or NZ-resident individuals — split-year, residence tie-breaker, and Indian foreign-asset reporting where required.
- Transfer pricing if associated Indian and NZ entities trade goods, services, IP, or intra-group finance.
How we keep both files on the same facts
- 1List owners, directors, where decisions are made, and every India–NZ payment.
- 2Characterise dividends, services, royalties, and finance under the DTAA.
- 3Align IRD numbers, Indian ITR, 15CA/CB, and FEMA papers.
- 4Review PE and residence if people or contracts move mid-year.
PJRJ’s international tax desk in Delhi and Gurgaon leads the analysis. NZ filings that must be signed locally stay with NZ partners. This page is general information, not an opinion on your residence or PE.
India–New Zealand Cross-Border Tax FAQs
No. Indian residents remain taxable on worldwide income unless a specific exemption applies. Treaty relief under the India–New Zealand DTAA, PE analysis, dividend characterisation, and FEMA ODI reporting still apply. We coordinate both files.
Discuss your India–NZ requirements
Speak with a PJRJ NZ desk partner — we respond within one business day.