US & NZ Sign Protocol to Income Tax Treaty
The Treasury Department announced today that Deputy Secretary Robert M. Kimmitt and New Zealand's Ambassador to the
United States Roy Ferguson signed a protocol updating the current income tax treaty between the United States and New
In a ceremony held at the Treasury Department, the two officials signed a Protocol that brings the existing tax treaty
into closer conformity with current U.S. tax treaty policy. The new agreement provides for the elimination of
source-country taxation of certain direct dividends, and interest paid to banks and other financial enterprises when the
payer of the interest is not a related party. The new protocol also reduces the existing treaty's limit on taxation of
cross-border payments of royalties to five percent.
The new protocol introduces a number of technical updates to the existing treaty, and also contains comprehensive and
modern rules regarding limitation on benefits, non-discrimination and exchange of information.
The final version of the unsigned protocol is attached.