When Your Business Grows Overseas
Tax issues to think about early....
Expanding overseas can create opportunities, but also new tax and compliance obligations. These can arise before an overseas company is established. Selling to foreign customers, employing people offshore, holding stock overseas or opening an office can all change the tax position.
Selling to overseas customers
Exported goods and many services supplied to non-residents outside New Zealand may be zero-rated for GST, provided the relevant requirements are met. Overseas customers do not automatically give every transaction the same GST treatment.
- Confirm that the customer is genuinely non-resident and that the particular supply qualifies for zero-rating.
- Retain appropriate records supporting the customer’s overseas status and the GST treatment applied.
Could another country tax the business?
A New Zealand company is generally taxed here on its worldwide income. Another country may also tax income where the business has created a sufficient presence there.
- A permanent establishment may arise through a fixed place of business, such as an office, branch or workshop.
- Staff permanently based overseas or substantial activities in another country may trigger local registration, filing or tax payment obligations.
- The outcome depends on local law and any applicable double tax agreement.
Employing someone overseas
Hiring an employee who lives and works overseas can involve more than paying salary from New Zealand. Consider:
- local payroll registration and withholding tax;
- social security and employment law obligations;
- company or tax registrations; and
- whether the employee creates a permanent establishment.
Advice should ideally be obtained before the employee starts work, when the arrangement can still be structured appropriately.
Overseas contractors
If an overseas contractor performs all work outside New Zealand and has no presence here, New Zealand non-resident contractor withholding rules generally do not apply. If the contractor works in New Zealand, payments may be subject to withholding tax, although exemptions or different rates may apply. Check the position before payment.
Holding stock overseas
Storing inventory in an overseas warehouse or fulfilment centre may improve delivery times, but can also trigger local income tax, GST, VAT or sales-tax obligations. Moving stock offshore is therefore both a logistics and a tax decision.
Overseas GST, VAT and sales tax
Depending on where and how the business sells, overseas registration may be required. This is particularly relevant for:
- online and e-commerce sales;
- digital services, software and subscriptions; and
- businesses holding inventory overseas.
Double tax agreements and foreign tax credits
New Zealand’s double tax agreements help determine which country may tax particular income and reduce the risk of double taxation. Foreign tax properly paid may also qualify for a New Zealand foreign tax credit. However, treaty and domestic rules must both be considered. A treaty does not automatically exempt overseas income from New Zealand tax.
Management and company residence
A New Zealand-incorporated company will generally remain New Zealand tax resident, but it may also become resident elsewhere depending on where directors exercise control, where central management occurs and the other country’s rules. This is especially relevant when owners or directors relocate overseas while continuing to manage the company.
Foreign currency
Exchange-rate movements between invoicing and payment can create foreign exchange gains or losses. Larger foreign currency balances, loans or long-term contracts may also engage the financial arrangement rules. Reliable accounting systems become increasingly important as transaction volumes grow.
Check the tax position before acting
Seek advice before:
- employing someone or opening an office overseas;
- Storing stock in another country;
- entering a major overseas contract;
- relocating key management; or
- sending employees or contractors across borders.
Overseas growth is positive, but tax should be part of the planning.
Ask where the business is operating, where its people work, where stock is held and which countries may now have taxing rights. Early advice can identify obligations and help structure expansion appropriately.











