Johnston Law

28/05/2026

Budget 2026 and financial arrangement rules for migrants

Today’s Budget includes a welcome and long-awaited proposal to reform New Zealand’s financial arrangements rules — particularly for individuals holding investments in foreign currencies.

These rules have long created uncertainty for internationally connected clients. Because income is recognised on an accrual basis, unrealised foreign exchange movements can drive tax outcomes that bear little resemblance to actual cashflow.

For migrant clients in particular, this has meant exposure to volatile and sometimes unexpected tax positions year to year.

The proposed changes are a constructive step forward.
Key points include:
*Allowing certain taxpayers to calculate income in a foreign currency, reducing exposure to unrealised FX movements
*Targeted relief where cross-border double taxation arises
*A tailored approach for Active Investor Plus visa holders to avoid “on-arrival” tax distortions
*Excluding lower-risk, everyday foreign currency arrangements (such as personal accounts and mortgages) from the regime altogether.

If enacted as proposed, these changes should significantly improve certainty, align tax outcomes more closely with economic reality, and make New Zealand a more workable jurisdiction for globally mobile individuals.

Further, we are pleased to see the FIF de-minimus has been doubled to $100,000, meaning those with FIF investments under $100,000 will no longer need to account under the complex FIF rules.

Best of all, in our opinion, is the extension of the RAM FIF method to all taxpayers.

From our perspective, these are sensible and pragmatic shifts — and reflects the increasing complexity of cross-border investment and migration.

As always, the detail will matter, particularly around eligibility and how these rules interact with existing regimes (including FIF and transitional residency).

We will be watching closely as legislation is introduced. These changes are not included in the budget Bill, so we will need to hope they are enacted prior to the election, or are re-introduced by the newly formed government.

15/05/2026

We are proud to show our support for Pink Shirt Day today 👚 It is an important reminder of the power of kindness, inclusion, and speaking up against bullying in all its forms. At Johnston Law, we believe everyone deserves to feel safe, respected, and valued - whether in the workplace, the classroom, at home, or in the wider community. By standing together, we can help create environments where people feel supported and heard - not just today, but every day.

Kōrero Mai, Kōrero Atu, Mauri Tū, Mauri Ora - Speak up. Stand together. Stop bullying.

24/04/2026

ANZAC Day 🌺
Today, we pause to honour the bravery and sacrafice of the men and women who have served our country.

Today, and always, we remember their courage and the enduring legacy they leave behind.

Lest we forget.

02/04/2026

Big news! 📣 Over years of advising migrants and expats, one thing became clear: clients need specialist support not only for legal advice, but also for the practical side of their tax obligations. We are pleased to officially launch Migrant Tax NZ - a dedicated accounting firm established to support migrants and expats with their practical tax and compliance needs. While Migrant Tax NZ has been working with clients behind the scenes for a couple of months, this marks its formal public launch. Johnston Law continues to provide legal advice, and Migrant Tax NZ provides accounting and tax compliance services. The two separate businesses work alongside each other to offer a coordinated and comprehensive service - giving clients access to both legal and accounting support in a streamlined, unified way from start to finish.
🔗 www.migranttax.nz

16/03/2026

Inland Revenue has been extremely active in the collection of unpaid tax in recent times. The release of Revenue Alert 26/01 yesterday reinforces this approach and makes it clear that PAYE deductions are not business money, with Inland Revenue taking a harder line on enforcement. Business owners and directors should be aware that using PAYE to manage cashflow can expose them to personal liability, including in serious cases criminal consequences. Our latest article explains what business owners need to know.

When you pay staff, you are required to deduct certain amounts from their wages (such as PAYE, KiwiSaver contributions, and student loan repayments) and pass those amounts on to Inland Revenue. Although the money moves through your business bank account, it is not business income. It belongs to your...

24/02/2026

A significant change is coming for people transferring their UK pension to a New Zealand QROPS. From 1 April 2026, eligible transfers will be able to access a new tax payment option known as “scheme pays”. While this change may be particularly beneficial for those on higher marginal tax rates, it also highlights the importance of correctly understanding New Zealand tax residency and the application of the foreign superannuation exemption period before any transfer takes place. You can read more about the changes and key considerations in our latest article:

From 1 April 2026, people transferring a UK pension to a New Zealand QROPS will be able to access a new tax payment option known as “scheme pays”. This change represents a significant shift in how overseas pension transfers are taxed in New Zealand and is expected to be particularly beneficial f...

20/02/2026

We are delighted to share that Johnston Law has been named ‘International Tax Law Firm of the Year – Christchurch 2025’ by Legal Insider Magazine. The Legal Insider Awards recognise excellence and innovation across the global legal profession, highlighting firms that demonstrate strong capability and impact within their specialist practice areas. We are proud to be acknowledged for our ongoing work in this area of tax law. This recognition reflects our continued focus on delivering high quality and practical advice for our clients.

International Tax Law Firm of the Year - Christchurch, 2025 Johnston Law specialises in providing expert tax advice and services to people with New

14/02/2026

Since this article was first published, Overseas Investment Act reforms have been passed and will take effect from 6 March 2026. The changes introduce a new consent pathway allowing AIP visa holders (and certain other investor visas) to purchase or build residential property in New Zealand valued at more than NZD$5 million. While this makes property ownership more accessible, it does not change New Zealand’s tax residency rules. Residential property ownership is still be a relevant factor when Inland Revenue assesses whether an individual has a “permanent place of abode” in New Zealand. Tax residency is extremely fact-specific and requires careful analysis of individual circumstances. If you or your investor clients are considering purchasing property, make sure the potential tax implications of acquiring property in New Zealand are considered. We regularly provide advice in this area, and are currently advising a number of AIP clients who will become eligible to own property, on the potential tax implications, and considering structuring for tax migration.

The Government has announced details of proposed legislation that will allow Active Investor Plus (AIP) visa holders to purchase (or build) residential property worth $5 million or more. However, with the excitement comes a crucial question; does purchasing such a property automatically make you a t...

13/01/2026

While we were back in the office last week, we know many people are starting back this week - we wish you all a smooth and productive start to 2026. We made sure to recharge over the festive period with some time in the sunshine, riding our horses together and soaking up this incredible view over the Canterbury Plains!

06/01/2026

After a refreshing Christmas break, we are back and already in full swing! Whether you’re relocating, managing cross-border interests, or need expert advice on expat tax, property tax, GST, or IRD matters (such as investigations and audits), we are here to help you navigate the complexities of the New Zealand tax system. We also provide support with relationship property matters, such as contracting out agreements (prenups) and separations. If you need assistance, please don’t hesitate to get in touch.