- Rental income from property located in New Zealand and held by either a New Zealand tax resident or a non-New Zealand tax resident; and
- Rental income from property located overseas and held by a New Zealand tax resident.
Where the rental is subject to tax based on the country of source and the country of residence, the double tax treaty should be considered.
Thin capitalisation rules may apply where a New Zealand tax resident’s funds are borrowed from cross-border related entity.