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United Kingdom

1983 agreement

Status: In force
Signed: 4 August 1983
In force: 16 March 1984
Effective: In New Zealand: From the income year beginning 1 April 1984.
In the United Kingdom: Income tax and capital gains tax, from 6 April 1984; corporation tax, from 1 April 1984; petroleum revenue tax, from 1 January 1984.
Refer to Article 27 of the agreement, as amended.
Legislation: Double Taxation Relief (United Kingdom) Order 1984 (New Zealand Legislation website)
National interest analysis: PDF (83KB) (see Appendix D, page 18)

Exchange of notes in relation to Article 27 of the 1983 agreement

Status: In force
Signed: 22 December 1983
In force: 22 December 1983
Effective: In New Zealand: From the income year beginning 1 April 1984.
In the United Kingdom: Income tax and capital gains tax, from 6 April 1984; corporation tax, from 1 April 1984; petroleum revenue tax, from 1 January 1984.
Refer to Article 27 of the agreement, as amended.
Legislation: Double Taxation Relief (United Kingdom) Order 1984 (New Zealand Legislation website)

Protocol to the 1983 agreement

Status: In force
Signed: 4 November 2003
In force: 23 July 2004
Effective: In the United Kingdom: Income tax, capital gains tax and corporation tax on gains referred to in Article V on 4 November 2003. In relation to information referred to in Article VII of the protocol on 4 November 2003. For any other income tax not described in the first sentence, 6 April 2005. For corporation tax not described in the first sentence, for any financial year beginning on or after 1 April 2005. And 6 April 2006 for tax credits as described in Article VIII.
In New Zealand: 4 November 2003 for income and gains referred to in Article V of the protocol. For information referred to in Article VII 4 November 2003. For all other tax for any income year beginning 1 April 2005.
Legislation: Double Taxation Relief (United Kingdom) Amendment Order 2004 (New Zealand Legislation website)

Second protocol to the 1983 agreement

Status: In force
Signed: 7 November 2007
In force: 28 August 2008
Effective: 28 August 2008
Legislation: Double Taxation Relief (United Kingdom) Amendment Order 2008 (New Zealand Legislation website)
National interest
analysis:		 PDF (86KB)

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS

Text: OECD website
Status: In force for New Zealand and the United Kingdom
Signed: 8 June 2017 [7 June 2017 in Paris, France]
In force: For New Zealand: 1 October 2018
For the United Kingdom: 1 October 2018
Effective:
The MLI comes into effect under Article 35(1) for a DTA from the latest of the dates on which the MLI enters into force for New Zealand and the United Kingdom:
  • for withholding taxes: from 1 January 2019 
  • for all other taxes: for taxable periods commencing on or after 1 April 2019
Legislation Double Tax Agreements (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting) Order 2018 (New Zealand Legislation website)
National interest
analysis		 Finance and Expenditure Committee report (includes NIA) (PDF 95 KB) (New Zealand Parliament website)
Additional information OECD information

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