Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the trust establishment, including banking and payment rails.
Set up a trust in New Zealand.
The onshore trust with offshore economics: the Trusts Act 2019 codified trustee duties and set a 125-year maximum duration, while the foreign trust regime keeps non-resident settlors' foreign income outside New Zealand tax - provided the trust registers with Inland Revenue, discloses fully and files annual returns. Compliance is the price of the exemption.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
New Zealand in brief
An OECD trust that earns its exemption.
New Zealand rewrote its trust law with the Trusts Act 2019 - a modern statute that codifies mandatory and default trustee duties, sets a maximum duration of 125 years, and defines what beneficiaries are entitled to know. On top of that sits the arrangement international families actually come for: the New Zealand foreign trust. Where the settlor is non-resident, foreign-source income of the trust sits outside New Zealand tax, but only if the trust is registered with Inland Revenue and stays compliant. Registration costs NZ$270 including GST (waived where all trustees are natural persons acting non-professionally), requires the trust deed, the settlor's full name, settlement details, and the names, roles, taxpayer identification numbers and addresses of connected persons, and annual returns keep the registration alive.
The sanction structure is what makes the regime credible: trustees who fail the disclosure rules lose access to the foreign-source income exemption and face civil penalties. That is the real trade - a first-world common-law jurisdiction, a respected statute and real banking, in exchange for genuine transparency to the tax authority. For families who want an onshore-quality trust without onshore taxation of foreign income, and who are prepared to be known to the regulator, the New Zealand foreign trust is one of the cleanest instruments available. We draft under the 2019 Act, register with Inland Revenue and run the annual compliance.
Onshore standing, offshore economics: the Trusts Act 2019 with codified duties and a 125-year maximum, plus the foreign trust regime - IRD registration at NZ$270 with full disclosure of settlor, settlements and connected persons, and annual returns.
Registered and compliant, foreign-source income stays outside NZ tax; fail the rules and the exemption is lost with a civil penalty on top. Disclosure is the product.
The two builds
The domestic trust - or the registered foreign trust.
Same statute, two tax worlds: the domestic trust for New Zealand families, the registered foreign trust for non-resident settlors. We build the second far more often.
The registered foreign trust - or the domestic instrument.
01 - NZ FOREIGN TRUST
The international structure
A trust with a New Zealand resident trustee and a non-resident settlor. Registered with Inland Revenue, fully disclosed, filing annual returns, and holding the foreign-source income exemption in return.
A trust with a New Zealand resident trustee and a non-resident settlor. Registered with Inland Revenue, fully disclosed, filing annual returns, and holding the foreign-source income exemption in return.
- ✓Non-resident settlor
- ✓NZ resident trustee
- ✓IRD registration - NZ$270
- ✓Deed and settlor disclosed
- ✓Connected persons with TINs
- ✓Annual returns maintained
02 - DOMESTIC NZ TRUST
The onshore instrument
The conventional family trust under the 2019 Act. Codified duties, beneficiary information rights and the 125-year horizon, taxed under New Zealand's domestic rules.
The conventional family trust under the 2019 Act. Codified duties, beneficiary rights, NZ taxation. For onshore families and assets.
- ✓Trusts Act 2019 duties
- ✓Mandatory and default duties
- ✓Beneficiary disclosure rights
- ✓125-year maximum duration
- ✓NZ taxation applies
- ✓Succession and protection uses
Registration fee NZ$270 including GST, waived where all trustees are natural persons not in the business of trusteeship. Reflects the Trusts Act 2019 and IRD requirements as of 2026.
Why New Zealand
Six reasons families choose the NZ trust.
✓
A modern statute
The Trusts Act 2019 codified trustee duties and beneficiary rights. The law is recent, readable and litigated in English.2019, codified duties.
✓
The foreign-source exemption
Registered foreign trusts keep non-resident settlors' foreign income outside New Zealand tax. The regime's entire point.Registered, conditional.
✓
Compliance that protects you
Registration and disclosure are the price, and the reason banks and advisers treat the structure as clean rather than suspect.Clean, not suspect.
✓
OECD standing
A first-world common-law state with real courts and real banking. Nothing about the flag needs explaining.Nothing to explain.
✓
125-year horizon
The Act allows trusts of up to 125 years. Multi-generational planning in one instrument.Generational horizon.
✓
Priced like a service, not a licence
NZ$270 to register. The cost sits in proper trusteeship and compliance, not in state fees.NZ$270 to register.
How it compares
How New Zealand differs from other trust jurisdictions.
The comparison, side by side: onshore standing with an exemption you keep by disclosing, not by hiding.
New Zealand vs other trust jurisdictions
| Feature |  New Zealand | Other jurisdictions |
|---|---|---|
| Statute | Trusts Act 2019 | 1984-2012 laws |
| Tax position | Registered exemption | No local tax at all |
| Transparency | IRD registration + returns | Registers vary |
| Standing | OECD onshore | Offshore or Crown Dependency |
Statute
New ZealandTrusts Act 2019
Other jurisdictions1984-2012 laws
Tax position
New ZealandRegistered exemption
Other jurisdictionsNo local tax at all
Transparency
New ZealandIRD registration + returns
Other jurisdictionsRegisters vary
Standing
New ZealandOECD onshore
Other jurisdictionsOffshore or Crown Dependency
Country by country
| Country | Instrument | Trustee regulation | Notes |
|---|---|---|---|
| New Zealand | Foreign trust - 2019 Act | IRD-registered structure | Exemption via disclosure |
 Jersey | Jersey trust - 1984 Law | JFSC trust company business | The benchmark |
 Guernsey | Guernsey trust | GFSC fiduciary licence | 56-day licence decision |
 Cyprus | International trust | CySEC-regulated ASPs | EU member state |
New ZealandInstrumentForeign trust - 2019 Act
Trustee regulationIRD-registered structure
NotesExemption via disclosure
JerseyInstrumentJersey trust - 1984 Law
Trustee regulationJFSC trust company business
NotesThe benchmark
GuernseyInstrumentGuernsey trust
Trustee regulationGFSC fiduciary licence
Notes56-day licence decision
CyprusInstrumentInternational trust
Trustee regulationCySEC-regulated ASPs
NotesEU member state
Before you establish
What a New Zealand foreign trust actually requires.What establishment requires.
The regime rewards completeness and punishes gaps. The checklist below is what a compliant establishment covers.
01
Trust deed. Drafted under the Trusts Act 2019 to the family's succession intention.
02
Resident trustee. At least one New Zealand resident trustee, professional in almost all cases.
03
Non-resident settlor. The condition that keeps foreign-source income outside NZ tax.
04
IRD registration. The NZ$270 application with the deed and amending documents attached.
05
Settlor disclosure. Full name and settlement details: type, date, amount and currency.
06
Connected persons. Names, roles, taxpayer identification numbers and addresses filed.
07
Beneficiary information. Discretionary and residual beneficiaries disclosed per the rules.
08
Annual returns. Filed on time, every year, to keep the registration and the exemption alive.
09
Trustee duties. The Act's mandatory and default duties observed and documented.
10
Source of wealth. Documented to the standard trustee and banks require.
11
Tax analysis. Settlor and beneficiary residence modelled in every relevant country.
01
Deed under the 2019 Act.
02
NZ resident trustee.
03
Non-resident settlor.
04
IRD registration filed.
05
Settlor fully disclosed.
06
Connected persons with TINs.
07
Beneficiaries disclosed.
08
Annual returns on time.
09
Duties observed, documented.
10
Source of wealth evidenced.
11
Tax modelled everywhere.
Non-compliance costs the exemption and can bring a civil penalty. Reflects the Trusts Act 2019 and IRD foreign-trust rules as of 2026.Trusts Act 2019 + IRD rules, as of 2026.
How it works
From first call to a registered NZ foreign trust.
01
Intention and map
Family, assets and residences, and whether disclosure-based planning suits this family at all.Disclosure suits you?
02
Design
Resident trustee, beneficiary class and the underlying holding structure designed together.Trustee and class.
03
Drafting
The deed under the Trusts Act 2019. Duties and mechanics specific to the case.Under the 2019 Act.
04
Registration
The IRD application with full disclosure. Processed within ten working days of a complete filing.10 working days.
05
Administration
Annual returns and records maintained. The exemption preserved by compliance.Returns, every year.
Quick facts
StatuteTrusts Act 2019
Maximum duration125 years
RegistrationIRD - foreign trust
FeeNZ$270 incl GST
Fee waivedAll-natural, non-professional trustees
Processing10 working days
Annual returnsRequired
SanctionExemption lost + penalty
The exemption is conditional every single year. An unfiled return is not a formality missed, it is the tax status of the whole structure at risk.
On the ground in New Zealand
Run from our Auckland office.
Prifinance - New Zealand
Auckland · New Zealand
Auckland, New Zealand
01
Intention first
Whether the NZ foreign trust is the right instrument. A strict gate before anything is drafted.Strict gate.
02
The deed
Drafted under the 2019 Act with duties, powers and distribution mechanics for this family.For this family.
03
Registration
The IRD application filed complete. Deed, settlor, settlements and connected persons in one pass.Complete in one pass.
04
Annual compliance
Returns, records and trustee duties maintained. The exemption kept, year after year.Exemption kept.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
Dubai
UAE
33 Level, Al Saqr Business Tower
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of New Zealand trusts.
The cleanest deal in the trust world: disclosure in exchange for exemption. With the analysis done where the family lives.
The foreign-source exemption
A registered, compliant foreign trust keeps non-resident settlors' foreign income outside New Zealand tax.Foreign income outside NZ.
Registration is the condition
The exemption attaches to registered trusts meeting the disclosure rules. Lose compliance, lose the exemption.Registered + compliant.
Civil penalties
Beyond losing the exemption, non-compliance can bring a civil penalty. The regime polices itself.Self-policing regime.
Residence rules abroad
Settlor and beneficiary home-country rules still apply. New Zealand solves its side, not theirs.Still apply abroad.
Domestic trusts differ
Trusts with resident settlors are taxed under New Zealand's domestic rules. A different instrument entirely.Resident settlors taxed.
Modelled before signing
Advisers in each relevant residence involved before establishment. The design survives contact with three tax systems.Advisers early.
Tax summary
Foreign-source incomeExempt if registered
ConditionRegistration + returns
Registration feeNZ$270 incl GST
Non-complianceExemption lost + penalty
Planning levelEvery relevant residence
*Position as of 2026 per Inland Revenue. Cross-border outcomes are modelled with advisers in each relevant residence before establishment.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: New Zealand structure, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a working trust.
Follow Prifinance
Active across our channels.
New Zealand · Trusts Act 2019
Set up your New Zealand trust with expert support.
Full-service assistance - from deed drafting and resident trustee to IRD registration and annual compliance - run through our Auckland office.
Get a consultation →Free legal opinion
Is a New Zealand trust right for your family?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, structure, or route fits your situation.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The New Zealand trust - what clients ask.
What law governs New Zealand trusts?+
The Trusts Act 2019 - a modern statute codifying mandatory and default trustee duties, beneficiary information rights and a maximum trust duration of 125 years.
What is a New Zealand foreign trust?+
A trust with a New Zealand resident trustee and a non-resident settlor, registered with Inland Revenue. Registered and compliant, its foreign-source income sits outside New Zealand tax - the regime international families use.
What does registration require?+
The trust deed and amendments, the settlor's full name and settlement details - type, date, amount, currency - plus names, roles, taxpayer identification numbers and addresses of connected persons, and details of discretionary and residual beneficiaries. The fee is NZ$270 including GST.
When is the fee waived?+
Where all trustees are natural persons not in the business of being trustees - a concession aimed at genuinely private arrangements rather than professional structures.
What keeps the exemption alive?+
Annual returns and continued compliance with the disclosure rules. Trustees who fail them lose access to the foreign-source income exemption and can face a civil penalty.
How fast is registration?+
Inland Revenue processes complete applications within ten working days - the preparation of full disclosure is what takes the time.
Is this a secrecy structure?+
The opposite - it is a disclosure structure. The trust is known to the tax authority in detail, and that is exactly why banks, advisers and foreign regulators treat it as clean.
How long can the trust last?+
Up to 125 years under the 2019 Act - ample for multi-generational succession planning.
New Zealand or a Crown Dependency?+
Jersey and Guernsey offer deeper fiduciary industries at higher cost; New Zealand offers OECD onshore standing with a registered exemption at service-level pricing. Family profile and adviser preference decide - we model both.
Why Prifinance for New Zealand?+
Deeds under the 2019 Act drafted for the actual family, IRD registration filed complete in one pass, and the annual compliance run so the exemption never lapses - from our Auckland office.
What law?+
Trusts Act 2019.
Foreign trust?+
Non-resident settlor, registered.
Registration?+
Deed, settlor, TINs - NZ$270.
Fee waived?+
All-natural trustees.
Keep exemption?+
Annual returns.
How fast?+
10 working days.
Secrecy?+
No - disclosure structure.
Duration?+
125 years.
Or Jersey?+
Standing vs depth.
Why you?+
Complete in one pass.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
Google
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Google
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Google
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: whether an NZ trust fits your family and what it will cost.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of Inland Revenue or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.