BorderFolio/NZ FIF changes 2026
NZ FIF changes: where the $100,000 threshold actually stands
Last reviewed 12 October 2026
Budget 2026 proposed doubling the foreign investment fund de minimis threshold to NZD 100,000, backdated to 1 April 2026. A bill carrying it was introduced in September. Then Parliament was dissolved before the bill got past select committee. If you are deciding what to do before 31 March 2027, the honest position is that the change is not law, its start date is already in the past, and whether it survives is now a question for the Parliament elected on 7 November.
The short version. The threshold in force today is NZD 50,000, measured on cost. The proposed NZD 100,000 is real, officially announced and drafted — but unenacted, and the bill carrying it lapsed when Parliament dissolved on 1 October 2026.
On this page
Status at a glance
| Measure | Proposed | Status as at 12 Oct 2026 |
|---|---|---|
| De minimis threshold | NZD 50,000 → NZD 100,000, from 1 April 2026 | Not enacted — bill lapsed on dissolution |
| Revenue account method | Extended to all NZ-resident individuals, from 1 April 2026 | Not enacted — same bill |
| Law actually in force | — | NZD 50,000 threshold, per IRD's IR461 (April 2026) |
The distinction matters more than usual here, because the proposed start date — 1 April 2026 — is already behind us. The 2026–27 tax year is being lived under one rule while a different one is proposed to apply to it retrospectively.
How it got here
- 28 May 2026 — Budget 2026. The Government proposed lifting the FIF de minimis threshold from NZD 50,000 to NZD 100,000, effective 1 April 2026. It would be the first increase since the threshold was set in 2000.
- 10 September 2026 — bill introduced. The Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill, an omnibus bill covering FBT, FIF, GST, cryptoassets, R&D and more.
- 15 September 2026 — first reading passed, and the bill was referred to the Finance and Expenditure Committee, which called for submissions.
- 23 September 2026 — Parliament's final sitting of the term.
- 1 October 2026 — Parliament dissolved. Business before the House lapsed.
- 7 November 2026 — general election. Advance voting opens 26 October; overseas voting from 21 October.
So the bill had exactly one reading and a few days of committee life before the term ran out.
What dissolution actually does to a bill
Lapsing sounds terminal and is not. Bills before the House lapse on dissolution, but the incoming House can reinstate them — and annual tax bills are routinely reinstated, because the rates in them have to be set. What a new government does get is the opportunity to look at the list and decide what it wants to carry on with.
The practical consequence is a window with no fixed end. The select committee's submissions portal was left open through the interregnum, with the public encouraged to make submissions by 1 December 2026 so that they are ready for the committee of the next Parliament; the new committee decides when submissions actually close, and when it reports back.
Two honest readings follow from that, and we are not going to pretend to know which lands:
- The threshold change is uncontroversial, costed and already drafted, so reinstatement with the 1 April 2026 start date intact is the unremarkable outcome.
- An omnibus bill reinstated by a differently composed Parliament is a bill that can be amended, including in its start dates.
If you want to influence it rather than wait on it, submissions are the mechanism, and the portal was deliberately kept open for that.
The other change: the revenue account method
The threshold got the headlines; the second FIF measure in the same bill matters more to a particular group.
The revenue account method (RAM) taxes qualifying holdings on realisation — dividends received, plus 70% of any realised gain on disposal of qualifying unlisted foreign shares, with 70% of a realised loss available against future RAM gains. The point of it is cashflow: the fair dividend rate method deems income of 5% of opening market value whether or not the holding paid anything, which is painful for illiquid unlisted shares that may not be sellable to fund the tax.
RAM already exists — it was introduced by the previous year's tax bill, enacted in March 2026, but limited to recent migrants and returning residents. The proposal in the lapsed bill opens it to all New Zealand-resident individuals (and to trustees where the principal settlor is a resident natural person) holding qualifying unlisted foreign shares, regardless of when they arrived, with a five-year consistency commitment once elected.
If you hold unlisted foreign shares — founder equity, employee shares in an overseas private company, an early stake in a startup that has not listed — this is the measure worth tracking. Note the "unlisted" qualifier: it is not an alternative to FDR for an ordinary portfolio of listed ETFs.
What this means before 31 March
No advice here, just the shape of the decision. The New Zealand tax year ends 31 March, and the threshold test is on the cost of your attributing interests on every day of the year — not at year end. That combination is what makes the uncertainty awkward rather than academic.
- If your cost base is under NZD 50,000, nothing about this changes your position.
- If it is over NZD 100,000, nothing about this changes your position either — you are inside the rules on both the current and the proposed threshold.
- If you sit between the two, you are the person this bill is about, and your 2026–27 obligations depend on legislation that does not exist yet. That is a conversation to have with an accountant now rather than in March.
Whichever bracket you are in, the records a FIF calculation needs are the same, and they are not the ones a performance chart keeps: cost per holding in NZD at the date of purchase, market value on the first day of the tax year, and purchases and sales within the year. We set that out in full on what the FIF rules need from a portfolio record.
The one thing worth doing regardless of how the bill lands is keeping the cost base current, because it is the input to the test under either threshold.
Limitations and sources
- This is news, not advice, and the position described is as at the review date above. A page about an unenacted bill goes out of date by design — check the current status before acting.
- Nothing here is a prediction of what the next Parliament will reinstate, amend or drop.
- The threshold in force is NZD 50,000, per Inland Revenue's Guide to foreign investment funds (IR461, April 2026). The NZD 100,000 figure is proposed.
- Parliamentary dates are from the dissolution of the 54th Parliament and the published election timetable; the bill's progress from the Finance and Expenditure Committee's call for submissions.
- BorderFolio does not calculate FIF income and does not file anything for you.
- See the investment & tax disclaimer.
Common questions
Is the NZ FIF threshold $50,000 or $100,000 right now?
NZD 50,000. That is the figure in force and the one stated in Inland Revenue's guide IR461, dated April 2026. The NZD 100,000 threshold was proposed in Budget 2026 on 28 May 2026 and drafted into a tax bill introduced on 10 September 2026, but that bill had only passed its first reading when Parliament was dissolved on 1 October 2026. Until it is enacted, the law is NZD 50,000, measured on the cost of your attributing interests.
Did the FIF bill die when Parliament was dissolved?
It lapsed, which is not the same as dying. Bills before the House lapse on dissolution and can be reinstated by the incoming House, and annual tax bills are routinely reinstated because the rates they set have to be in place. What is genuinely unknown is the timing and whether a differently composed Parliament amends the bill, including its start dates.
Will the $100,000 threshold still apply from 1 April 2026 if it passes later?
That is what the bill proposes — the higher threshold applying from 1 April 2026, which is a start date already in the past. Retrospective start dates are ordinary in tax legislation, so a later enactment does not by itself move the date. But a lapsed bill can be amended on reinstatement, so the start date is not guaranteed until the legislation passes.
What is the revenue account method and who can use it?
It taxes qualifying holdings on realisation — dividends received plus 70% of any realised gain on disposal of qualifying unlisted foreign shares, with 70% of a realised loss available against future RAM gains. It was enacted in March 2026 but limited to recent migrants and returning residents. The lapsed bill proposed extending it to all New Zealand-resident individuals, and to trustees where the principal settlor is a resident natural person, with a five-year consistency commitment. It applies to unlisted shares, so it is not an alternative to the fair dividend rate method for a portfolio of listed ETFs.
What should I do if my overseas holdings sit between $50,000 and $100,000?
Speak to a New Zealand tax adviser rather than waiting for the bill, because the test is on the cost of your attributing interests on every day of the tax year and the year ends 31 March. That bracket is precisely the group whose 2026-27 obligations depend on legislation that does not exist yet. Keeping an accurate NZD cost base per holding is useful under either threshold, since it is the input to the test in both cases.
Can I still make a submission on the bill?
The Finance and Expenditure Committee's submissions portal was left open through the period between Parliaments, with the public encouraged to submit by 1 December 2026 so that submissions are ready for the committee of the next Parliament. The new committee decides when submissions close and when it reports back, so the practical advice is not to wait on a published deadline.