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Tax simplification in practice: three years of incremental reform

Tax Alert - July 2026

By Robyn Walker



While Deloitte’s Global Tax Policy Survey indicates that compliance costs are on the rise for multinational businesses, when it comes to New Zealand’s domestic law, the current Government has had a sustained focus on lowering compliance costs and removing barriers to investment.

The current Minister of Revenue, Hon Simon Watts, has taken the view that New Zealand’s tax system is broadly fit for purpose. Rather than pursuing wholesale changes to tax bases, the Government has focused on incremental, practical changes to address issues as they arise.

Many of these changes address small irritants. Individually, they may appear modest, but collectively they point to a shift away from using tax policy to influence behaviour, such as the previous denial of interest deductions for residential property, and towards making tax easier to comply with. The residential solar power exemption is one example. Proposed changes to the fringe benefit tax treatment of motor vehicles and non-resident contractors tax may also materially reduce compliance effort.

Looking back over the last three years, there have been many tax policy changes which have helped incrementally improve the tax system. This article highlights some of the more significant taxpayer-favourable changes from the last three years.

Budget 2026 announcements

Budget 2026 included a wide range of tax announcements, some of which have already been enacted, and others which are expected to be included in a taxation bill before Election 2026.

Change

Status

Impact

Fringe benefit tax reform for motor vehicles: amend the way FBT applies to motor vehicles to better focus the tax on scenarios where there is a benefit being received by the employee. Change the rules so that the type of vehicle doesn’t influence whether exemptions are available. Reduce rates of tax on hybrids and electric vehicles. 

Proposal

Reduced compliance costs and fairer tax outcomes.

Membership subscriptions and levies: the law will be changed to reinstate the status quo for membership bodies and not-for-profits after a change in Inland Revenue interpretation of the law. 

Proposal

Reduced compliance costs.

Tax-free threshold for not-for-profits: the law currently effectively allows not-for-profits to earn up to $1,000 of net income and remain outside of the tax net. This threshold will be increased to $10,000. It will also be confirmed in legislation that income tax returns are not required to be filed by not-for-profits below the $10,000 threshold.

Proposal

Reduced compliance costs.

Donation tax credits: allow individuals to receive donation tax credit refunds during the year rather than needing to wait until an income tax return is filed. A mechanism will be introduced to allow donors to transfer a donation tax credit to the charity. 

Proposal

Reduced compliance costs.

Non-resident contractors tax exemption for aircraft leasing: because contracts require New Zealand customers to gross up payments for tax, a change has been made to exempt such payments from NRCT.

Enacted

Removal of an unnecessary tax cost.

Non-resident contractors tax: increase the de minimis exemption from $15,000 to $75,000 to allow small contracts to be excluded from NRCT, and introduce a single payer view to make it easier to assess whether NRCT applies. It is proposed to exempt certain low risk entities (which are already filing New Zealand tax returns) from the NRCT regime. 

Proposal

Reduced compliance costs and fairer tax outcomes.

Working For Families: removal of some of the complexities in the regime to make it fairer.

Enacted

Reduced compliance costs.

Foreign Investment Fund rules: expand the ability to use the “revenue account method” to New Zealand taxpayers and increase the FIF de minimis threshold from $50,000 to $100,000.

Proposal

Reduced compliance costs and fairer tax outcomes.

Financial arrangements: allow some taxpayers to remove foreign exchange rate volatility from financial arrangement calculations.

Proposal

Reduced compliance costs and fairer tax outcomes.

Research and Development Tax Incentive: all tax credits to be received during the year rather than having a long delay. The Commissioner will be given a discretion to accept late returns and amend minor administrative errors. The mining sector will be able to access the RDTI on an equal footing with other industries.

Proposal

Reduced compliance costs and fairer tax outcomes.

Taxation (Annual Rates for 2025–26, Compliance Simplification, and Remedial Measures) Act 2026

This amendment Act included over 80 amendments, which were generally intended to remove barriers to investment, simplify tax rules, or ensure tax rules apply as intended.

Change

Impact

Digital nomads: exemption from tax for individuals temporarily in New Zealand and working for a foreign employer, or who are self-employed.

Reduced compliance costs.

Foreign Investment Fund rules: introduction of the “revenue account method” to reduce the negative impact of the FIF rules on new migrants and returning New Zealanders. 

Reducing barriers to taxpayers remaining in New Zealand and fairer tax outcomes.

Thin capitalisation rules for infrastructure investment: an exemption from the thin capitalisation rules for qualifying infrastructure projects financed by third party debt.

Reducing a barrier to investment in New Zealand.

GST and joint ventures: an amendment to allow the GST treatment of joint ventures to match historic treatment following a contrary Inland Revenue interpretation.

Reduced compliance costs.

Employee share scheme deferral regime: allowing employers and employees to elect to defer the taxing point under an employee share scheme until there is a liquidity event.

Reducing barriers to using employee share schemes.

Income tax exemption for the sale of residential solar power: introducing a tax exemption to remove the need to otherwise pay tax on amounts received from selling solar power into the grid.

Reduced compliance costs.

Income tax debt pilot using tax pooling industry: introducing a new temporary option for historic income tax debt to be repaid using tax pooling funds.

Providing an incentive for tax debt to be dealt with.

GST record-keeping requirements: removing the need for businesses selling goods valued at more than $1,000 to end consumers to collect purchaser details.

Reduced compliance costs

Gift cards and FBT: amending the law to ensure gift cards are subject to FBT (but also allowing employers to choose to pay PAYE if they prefer) after an Inland Revenue interpretation indicating that PAYE applied. 

Reduced compliance costs.

FBT vs PAYE: amending the law to make it easier for an employer to choose to pay tax through FBT rather than PAYE when reimbursing employees.

Reduced compliance costs.

FBT and personal protective equipment: amending the law to ensure that FBT does not apply to protective clothing such as hard hats.

Reduced compliance costs and fairer outcomes.

Financial arrangement rules: increasing thresholds to allow more taxpayers to use the simpler ‘cash basis person’ rules and repealing the need to undertake deferral calculations.

Reduced compliance costs.

Alignment of contractor definition: amending tax law to ensure that specified contractors under the Employment Relations Act are also contractors for tax purposes.

Reduced compliance costs.

Taxation (Budget Measures) Act 2025

Change

Impact

Investment boost: ability to claim an upfront 20% investment boost deduction on the cost of new assets. 

Reduced barriers to purchasing new assets. The incentive applies broadly in a low-compliance-cost way.

Taxation (Annual Rates for 2024‍–25, Emergency Response, and Remedial Measures) Act 2025

This amendment Act included over 80 amendments, which were generally remedial in nature and designed to ensure tax rules apply as intended. 

Change

Impact

Emergency response rules: creation of a set of tax concessions which can be easily switched on and off in the event of emergencies.

Reduced compliance costs and increased certainty.

Approved Issuer Levy: allowing securities to be retrospectively registered when minor historical errors have prevented the AIL regime from applying.

Reduced compliance costs.

Overseas pensions: addressing issues that affect the transfer of pension funds to New Zealand.

Reduced compliance costs.

Exempt employee share schemes: increased thresholds to allow higher values of shares to be offered to employees.

Reduced compliance costs.

Wide range of remedial GST changes: 23 changes were made to tidy up minor issues with the GST Act.

Reduced compliance costs.

Health and safety benefits: introducing an exemption from PAYE for health and safety benefits to match the FBT exemption. This makes it easier for employers when trying to provide benefits like flu injections.

Reduced compliance costs.

Bright-line test: a number of amendments to ensure the bright-line test works as intended.

Reduced compliance costs.

Research and development: extending the due date for RDTI general approvals.

Reduced compliance costs.

Taxation (Budget Measures) Act 2024

Change

Impact

Personal income tax changes: the Budget contained the first substantive changes to personal tax thresholds for many years.

Tax savings for individuals.

Research and Development Tax Incentive error correction: a change to allow the Inland Revenue to accept an RDTI application when it was made in the wrong taxpayer name.

Fairer tax outcomes.

Taxation (Annual Rates for 2023–24, Multinational Tax, and Remedial Matters) Act 2024

This Bill was first introduced under the previous Labour Government. Only changes added to the Bill after the change in Government are listed below.

Change

Impact

Restoring interest deductibility: the rules which denied interest deductions for landlords were repealed.

Fairer tax outcomes and reduced compliance costs due to the complexity of the repealed rules.

Bright-line test changed to 2 years: the bright-line test was simplified by returning it to be for a two-year period rather than a 10-year period. 

Reduced compliance costs due to the complexity of the 10-year rule.

Donated trading stock: an amendment was made to trading stock rules to ensure that when businesses donate stock (for example to charities) it does not create an income tax liability for the donor.

Reduced barrier to social good, fairer tax outcomes, and reduced compliance costs.

If you have questions about any of these items, please contact your usual Deloitte advisor. 

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