Welcome to our latest update on the New Zealand Active Investor Plus (AIP) visa, where we break down the key changes you can expect in 2026.

In our latest edition, we highlight new opportunities, important tax considerations, and what these developments mean for AIP investors.

Easier to buy residential property - but take care to not become a tax resident!

Currently AIP visa holders can only purchase residential property in New Zealand if they are ordinarily resident or intend to become ordinarily resident. This requires at least 12 months' presence and tax residency, which is not an option for many AIP visa holders.

Property purchase changes

The good news is that a recent law change removes these requirements for AIP visa holders who buy or build one home with a value of at least NZ$5 million, provided that home meets certain qualifying criteria. While consent from the Government will be required, there are lower application fees, shorter processing times, and limited grounds for refusal. This change comes into effect on 6 March 2026.

Tax implications

This good news comes with a tax warning. A critical consideration is that New Zealand tax residency isn’t just triggered by being present for more than 183 days over a 12-month period. Acquiring a “permanent place of abode” in New Zealand can also trigger tax residency, even if the person also has a permanent place of abode elsewhere.

Relevant factors include continuity and duration of presence, and the durability and closeness of association with the property. The longer a person is present in New Zealand, the more likely it is that their place of abode is permanent. Conversely, the longer a person is absent from New Zealand, the less likely it is that their place of abode will be a permanent place of abode.

Ahead of buying a home, AIP visa holders should seek tax advice on whether the home could constitute a permanent place of abode. We have been advising clients on this, and can seek a binding ruling from Inland Revenue for certainty.

New concessionary tax rules for tax resident migrants

New Zealand tax residents with less than 10% interests in foreign entities can be taxed on deemed income under the foreign investment fund (FIF) rules, regardless of distributions received. This is often an unwelcome surprise for migrants.

The most common FIF method is the ‘fair dividend rate', deeming taxable income to arise of 5% of the offshore portfolio's market value at 1 April each year.

The new revenue account method (RAM) will soon be available to new migrants who become tax resident in New Zealand. Legislation is due to pass by 31 March 2026, effective retrospectively from 1 April 2025.

Based on the draft law, if an AIP visa holder elects to use the RAM to account for FIF income:  

• they will still be exempt from tax on FIF income and dividends during their transitional residency period (usually 4 years); 
• once their transitional residency period ends, they will be taxed on dividends received and on realised gains on disposals (discounted by 30%); and 
• if they cease being tax resident, and they do not sell their FIF interests within three years, then no FIF exit tax will be payable. 

Most AIP visa holders can only use the RAM for ‘illiquid’ equity investments (e.g., unlisted shares), but US citizens can use it for all FIF interests, including listed equities.

The Government is also considering concessionary changes to the financial arrangement rules for new migrants, which spread income from debt investments over their life on an accrual basis, with announcements expected during 2026.