How to raise NZD 4–12.5 billion per year without taxing a single Kiwi one cent.
Extend New Zealand's existing transitional tax residency rules by up to 16 years, in exchange for a flat-tax payment. OECD‑compatible. Proven in Italy, Switzerland and the UK. Nothing new required.
Ministers & MPs: contact the author to book a personal briefing.
The proposal in plain language.
If you only have four minutes, start here. Short video briefing on what AIP+TRE does, why it matters now, and how it produces revenue without taxing a single Kiwi one cent.
Read the Full Proposal
Complete evidentiary base, costings, and implementation plan.
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erik@aip-tre.org.nz →AIP is the world's best backup‑plan visa. TRE converts AIP holders to tax‑paying residents.
New Zealand's Active Investor Plus visa has been a smashing success. But there's a serious problem: AIP is viewed solely as a backup‑plan visa by international wealth advisers, because New Zealand's post‑transitional tax settings rule New Zealand out from consideration for tax residency by ultra‑high‑net‑worth investors — investors who could bring billions of dollars of investment capital to help build the hospitals, roadways, bridges and schools New Zealand desperately needs.
This policy proposal describes how New Zealand could raise between NZD 4 and 12.5 billion per year in new Crown tax revenue — without taxing a single Kiwi. It proposes to extend New Zealand's existing transitional tax residency rules by up to 16 years, in exchange for a flat‑tax payment. Similar programmes have been very successful in other OECD countries such as Switzerland, Italy and the UK.
The entire case is in a single document: you can download the full proposal or watch the 4‑minute brief.
TRE unlocks the door and puts up a welcome sign.
AIP has already built the pipeline. The foreign income just isn't taxed.
Every major firm gives the same advice.
Every major New Zealand advisory firm gives the same counsel to ultra‑high‑net‑worth clients: do not establish tax residency in New Zealand, or plan to leave before Month 49. This is not one firm's opinion. It is the unanimous professional consensus of every major advisory practice in the country.
AIP gets wealthy households to New Zealand's front door — but our post‑transitional tax settings keep that door locked. For a UHNWI with meaningful foreign income, establishing full New Zealand tax residency today is an expensive mistake, and the professional advisory industry is unanimous that clients should avoid it.
This is not a failure of AIP. AIP does exactly what it was designed to do. The failure is downstream: when the four‑year transitional residency window closes, New Zealand's tax settings become an unforced error for any household with significant offshore capital. The result is that capital stays offshore, the households leave, and Crown revenue from this cohort rounds to zero.
TRE fixes only that downstream step. It does not change what any New Zealander pays. It does not change who is admitted to New Zealand. It extends a bridge that already exists — and asks participants to pay handsomely for it.
Extend what New Zealand has had for 20 years.
TRE is tax architecture, not immigration policy. It is visa‑neutral: participants first qualify for New Zealand transitional residency through an existing pathway — AIP, or any other route that confers transitional residency — and their screening, already adopted and tested, remains the safeguard. TRE then extends New Zealand's existing transitional residency rules by up to 16 years, in exchange for a flat annual contribution. Participants pay full standard NZ tax on all domestic income. Full proposal (PDF) contains the detailed mechanics.
Statutory grandfathering
All terms locked at election for the full 16‑year term by Act of Parliament. Converts policy into contract.
OECD‑compatible
Extends New Zealand's existing transitional residency — already OECD‑blessed. Italy and Switzerland already operate equivalent programmes.
NZD 5M mandatory NZ investment
In NZ growth assets from first repricing, additional to AIP visa investment. Capital goes to work in New Zealand.
US Track (FTC‑compatible)
Deemed income formula for NZ's largest source cohort — 40% of AIP applicants. Americans can participate without forfeiting US Foreign Tax Credits.
Voluntary incentive (QGI)
Scales to NZD 100M at maturity. Each tranche reduces contribution by 10%. At full deployment, participant pays full NZ income tax on domestic returns instead.
Not an immigration pathway
TRE is tax architecture only. Participants enter New Zealand through an existing visa route — AIP or another pathway conferring transitional residency — which retains its own screening. TRE changes nothing about who is welcome.
What New Zealand receives. What participants commit to.
The full structure in one page. You can also download the complete proposal for the detailed evidentiary base, costings and implementation plan.
A generational opportunity, measured in months.
For the first time in history, the world's wealthiest families are actively leaving their birth countries. This is not cyclical. It is a structural transformation of the global wealth map — and New Zealand is not currently on the short list.
How the revenue is produced, precisely.
Most tax‑residency incentive programmes either (a) tax foreign income at standard rates and watch wealth migrants leave, or (b) exempt foreign income entirely and draw international criticism. TRE does neither. It extends New Zealand's existing transitional residency regime, which the OECD has already reviewed, and attaches a flat contribution that produces real Crown revenue from day one. The mechanics are deliberate and worth reading carefully — the short summary:
NZD 600,000 at launch, scaling to NZD 1M+ per participant per year.
Participants elect TRE at AIP grant. From that election, each pays a flat annual contribution in lieu of tax on foreign income. The contribution is grandfathered at the election‑year rate for the full 16‑year term by Act of Parliament — converting what would otherwise be tax policy subject to change into something closer to a binding contract.
The launch rate is NZD 600,000. Repricing takes the rate to NZD 1,000,000+ at programme maturity. NZ‑sourced income remains fully taxable at standard rates throughout. There is no special treatment for domestic earnings.
The formula that keeps 40% of AIP applicants in the programme.
Roughly 40% of AIP applicants are US citizens, and US tax law creates a problem for them that most golden‑visa programmes ignore: a flat foreign‑tax payment isn't creditable against US tax unless it's structured as an income tax. If a US citizen pays a flat fee in Italy or Switzerland, they pay it on top of their US federal tax bill — not instead of part of it.
TRE's US Track solves this with a deemed‑income formula that allows the contribution to qualify for US Foreign Tax Credit treatment. The result: American participants don't pay tax twice. Without this, TRE would lose access to its largest source cohort.
Putting capital to work in New Zealand, by choice.
Qualifying Growth Investment (QGI) is a voluntary incentive, not a requirement. Each incremental tranche invested in qualifying NZ growth assets reduces the annual contribution by 10%. At full deployment — NZD 100M in QGI at programme maturity — the contribution goes to zero, and the participant instead pays full standard NZ income tax on their domestic returns.
This is the critical inversion: at the top of the QGI ladder, the participant is a normal NZ taxpayer on the capital they've chosen to deploy domestically. The more capital deployed in New Zealand, the more the participant's tax profile converges on a standard NZ resident. QGI is capital formation with a feedback loop.
1,440 days over 16 years — OECD‑compatible from the start.
Participants commit to 1,440 cumulative days of physical presence in New Zealand over the 16‑year term (approximately 90 days per year on average, with carry‑forward). This is above the OECD's guidance threshold for economic substance and well above the physical‑presence requirements of most comparable programmes.
Unlike tax‑haven structures, TRE participants are present in New Zealand. They spend. They employ. They integrate. And — because the entire structure is an extension of New Zealand's existing transitional residency rather than a novel exemption — there is no new bilateral tax treaty renegotiation required.
The four questions every MP asks first.
No. Not one. TRE applies only to a specific, self‑selecting group of incoming AIP visa holders who elect the programme at grant. All NZ‑sourced income is taxed at full standard rates. No domestic tax band, deduction, credit, or rate changes. The revenue is entirely additive — it comes from foreign income that is currently taxed at zero because these households simply leave, or never come in the first place.
TRE participants pay NZD 1M+ per year at programme maturity in a flat contribution and commit NZD 5M in mandatory NZ investment — on top of the NZD 5M–10M AIP visa minimum. Per participant, the NZD 1M+ flat contribution (at programme maturity) alone equates to the combined income tax of roughly 130 median-wage New Zealanders — every year, for 16 years. On top of that, participants pay full standard NZ tax on every dollar of NZ-sourced income. That is not a loophole. That is a premium.
No. TRE extends New Zealand's existing transitional residency rules, which have operated for 20 years and are already recognised by the OECD. Italy and Switzerland operate equivalent programmes today. Italy's Regime 24-bis and Switzerland's forfait fiscal are the closest analogues, and both are OECD-member programmes that have operated successfully for years. The UK's non-dom regime raised billions annually before the current government abolished it — and within nine months of abolition, 16,500 millionaires had left the UK. That is the outcome TRE is designed to avoid. We are not inventing anything.
Existing visa screening handles that problem already. TRE is tax architecture bolted onto New Zealand's existing transitional residency regime. Every TRE participant must first qualify for NZ transitional residency through an existing pathway — AIP or another route that confers transitional residency — and the screening attached to that pathway (character, source of funds, security) is the safeguard, exactly as it is today. TRE changes nothing about who is admitted. It changes what happens to the households already admitted on Month 49 and beyond.
The full case, in three formats.
The full proposal contains the complete evidentiary base, costings, OECD compatibility analysis and US Track mechanics. The intro deck is a 15‑minute briefing. The paperback is for ministers who prefer to read on the plane.
The Full Proposal
The complete evidentiary base: source‑country breakdown, composition of the migrating population, the American dimension, costings and implementation plan.
Download Full Proposal (PDF)Intro Deck
A slide deck covering the same structure at a ministerial briefing pace. Ideal for staff review before a meeting.
Download Deck (PDF)Paperback Edition
For ministers and MPs who prefer the printed form. Order direct from Amazon Australia with fast NZ shipping.
Order on Amazon (Paperback)For Ministers and MPs who would like a personal briefing.
AIP+TRE is a policy proposal, not a commercial venture. Briefings are offered at no cost to Ministers, MPs, party leadership, senior officials and caucus members. Reply directly to the author.
erik@aip-tre.org.nz