Singapore vs New Zealand tax for entrepreneurs: 2026

If you're a New Zealand founder weighing a move to Singapore, the rates make it look like an easy call. The harder part is everything in between: the year you rent out the house in Auckland, the NZ company you're not ready to close, the co-founder who stays behind. New Zealand tax has a view on all of it.

This one is personal for us. Our founding partner Matt is a New Zealander and a CAANZ chartered accountant who moved to Singapore in 2014, and Harvest is a corporate partner of the New Zealand Chamber of Commerce Singapore (we joined in January 2026). As a Singapore firm, we cover the Singapore side in detail and flag the New Zealand questions to put to a NZ tax adviser.

Singapore vs New Zealand tax at a glance

Corporate tax: 17% vs 28%, and what new companies actually pay

New Zealand taxes resident companies at 28% on worldwide income. Singapore's headline rate is 17%, and the start-up tax exemption cuts it further for a new company's first three Years of Assessment. It needs Singapore tax residence and no more than 20 shareholders, and excludes investment holding and property development companies. From year four, the partial tax exemption applies: 75% of the first S$10,000 and 50% of the next S$190,000.

For YA 2026, IRAS also grants a one-off rebate of 50% of tax payable, capped at S$40,000 including a S$2,000 cash grant for companies that paid CPF for at least one local employee in 2025. A brand-new company with no local staff still gets the rebate, but not the grant.

Here is what the same profit costs in each country

Figures are in each country's own currency, before the YA 2026 rebate.

Paying yourself: salary, director's fees and dividends

Singapore runs a one-tier system: once the company has paid its tax, dividends are tax-free for the shareholder and Singapore charges no dividend withholding tax (our dividend tax guide covers the mechanics). New Zealand uses imputation: the company pays 28% and attaches credits, and a NZ-resident shareholder tops up to their marginal rate. A Singapore dividend carries no imputation credit, so a founder who is still NZ-resident pays up to 39% on the whole amount.

Salary is taxed at Singapore's resident rates, from 0% on the first S$20,000 to 24% above S$1 million. New Zealand's rates from 1 April 2025 run 10.5% to NZ$15,600, 17.5% to NZ$53,500, 30% to NZ$78,100, 33% to NZ$180,000 and 39% above that, plus the ACC earners' levy of 1.75% on earnings up to NZ$156,641 for the year to 31 March 2027.

Here is an example. On a salary of 200,000 in each country's currency, a founder pays about S$21,150 in Singapore (10.6%) against roughly NZ$57,100 plus NZ$2,741 of ACC levy in New Zealand (about 30%).

Four payroll points catch relocating founders:

• CPF: Employment Pass holders do not contribute. CPF starts if you become a permanent resident.
• Skills Development Levy: the company pays 0.25% of each employee's monthly wages, foreigners included, between S$2 and S$11.25 a month.
• Director's fees: taxed at resident rates if you are tax resident; a non-resident director's fees generally carry 24% withholding tax.
• Year-end forms: the company reports your pay on Form IR8A by 1 March, and files Form IR21 tax clearance before a foreign employee stops work or leaves Singapore for more than three months.

When New Zealand stops treating you as resident

New Zealand treats you as resident if you spend more than 183 days in NZ in any 12-month period or keep a permanent place of abode there. Becoming non-resident takes more than 325 days away in a 12-month period and no permanent place of abode; once both are met, non-residence generally runs from the first day of that absence. Until then, New Zealand taxes your worldwide income. The family home, even rented out, can keep you NZ-resident.

Singapore treats you as tax resident after 183 days here in a calendar year, and IRAS has concessions for foreign employees whose stay spans two or three years. So in the move year you can be resident in both. The treaty's tie-breaker then looks at where you have a permanent home, then where your personal and economic ties are closer.

Salary for days you work in New Zealand, even on a trip back, can be taxed there. Keep a log of your days in each country, with the lease, travel records and employment contract that support it.

Where your company is resident: control and management

A Singapore company is tax resident in Singapore when its control and management, in practice the board's strategic decisions, are exercised here. New Zealand applies a mirror test: a company whose directors run it from New Zealand can be NZ tax resident, taxed at 28% on worldwide income, wherever it was incorporated.

Picture a founder who incorporates here, appoints a nominee director and makes every real decision from Auckland. That company risks dual residency and losing the start-up exemption. Minuted board meetings in Singapore help, but IRAS looks past them to where strategic decisions are actually made. Give your resident director a real role, and never backdate minutes.

If you stay a NZ resident: CFC and FIF rules

If you remain NZ-resident and own a Singapore company, the controlled foreign company rules apply. A company is a CFC when five or fewer NZ residents hold more than 50%, or one NZ resident holds 40% or more with no unassociated non-resident holding more; any NZ resident with a 10% income interest is in scope.

The active business test is the one to watch. If less than 5% of the CFC's gross income is passive (interest, rent, royalties, certain dividends), nothing is attributed and profits are not taxed in NZ until paid out. Fail it and the passive share is taxed at your marginal rate, with a credit for Singapore tax. Either way, you disclose the interest on form IR458 each year.

Holdings below 10% fall under the foreign investment fund rules, which by default tax a deemed 5% return on the shares' opening value each year, whether or not you received anything. Interests costing under NZ$50,000 are exempt. Budget 2026 proposes raising that to NZ$100,000 from 1 April 2026, and the bill was introduced on 10 September 2026, so check whether it has passed.

Keeping a NZ company, or working from New Zealand

Some founders keep the New Zealand company running, with its staff and customers, as a subsidiary of the new Singapore company. Plan for three things.

1. Transfer pricing. Management fees, IP licences and loans between the two companies must be priced at arm's length in both countries. Singapore requires formal transfer pricing documentation once gross revenue passes S$10 million and related-party transactions pass set thresholds, but the arm's-length rule applies at any size.
2. Dividends up the chain. Dividends from the NZ subsidiary can reach the Singapore parent free of Singapore tax under the foreign-sourced income exemption: New Zealand's 28% rate clears the 15% headline-rate test, provided the profits were taxed there and the other conditions are met. Fully imputed dividends can leave New Zealand with no withholding tax; otherwise the treaty caps it.
3. Staff left behind. Employees working in New Zealand generally stay on NZ PAYE, whichever company employs them, and KiwiSaver and ACC obligations can follow.

Working from New Zealand yourself carries a separate risk. If you habitually negotiate and sign contracts for the Singapore company from a NZ home office, it can have a permanent establishment in New Zealand, and the profits linked to that work become taxable there. Moving IP or shares out of the NZ company has its own valuation and tax consequences, so get NZ advice before you do it.

The Singapore-New Zealand tax treaty

The double taxation agreement was signed on 21 August 2009 and entered into force on 12 August 2010. Both countries have adopted the OECD Multilateral Instrument, which adds a principal-purpose anti-abuse test.

Because Singapore charges nothing on outbound dividends, the dividend caps only bite on money flowing from New Zealand, where non-resident withholding tax otherwise applies. Singapore's own withholding tax on interest and royalties paid to NZ drops to the treaty caps; our withholding tax guide covers it. To claim treaty rates, the Singapore company may need an IRAS Certificate of Residence.

Your first three years after the move

Before you leave New Zealand

1. Decide what happens to the house and to the NZ company: keep it as a subsidiary, sell it or wind it up.
2. If any co-founder or investor stays NZ-resident, get a written CFC and FIF analysis of the cap table before you incorporate.

Year one in Singapore

1. Incorporate through ACRA's BizFile. Government fees total S$315, and most registrations are approved soon after payment.
2. Appoint a Singapore-resident director and, within six months, a company secretary. If you are relocating, run the work-pass application in parallel; our EP, LOC and EntrePass guide walks through the options.
3. Open a bank account, set up Xero from day one, and hold your first board meeting in Singapore.
4. Start your day log, and file IR458 in New Zealand if anyone connected to the company remains NZ-resident.

We handle steps 1 to 3 through our company incorporation service, including Xero setup and the first year's filings.

Years two and three

The start-up exemption runs for the first three Years of Assessment, so model the salary-versus-dividend split each year while it lasts.

Common mistakes New Zealand founders make

The rates are the easy part. These are the traps that cost people:

1. Assuming the move alone cuts your tax. The saving holds only once you are genuinely non-resident. Keep a permanent place of abode in New Zealand, and a family home that stays available to you counts, and New Zealand still taxes your worldwide income, including Singapore dividends at up to 39% with no imputation credit.

2. Running the Singapore company from New Zealand. If the real decisions are made from Auckland, both countries can claim the company: IRAS may deny Singapore residence and the start-up exemption, and New Zealand's mirror test can tax it at 28%. A nominee director with minuted meetings does not fix a company actually run from NZ.

3. Ignoring CFC and FIF while anyone stays NZ-resident. If you, a co-founder or an investor stays New Zealand tax resident, the Singapore company is a controlled foreign company: passive income above the 5% threshold is attributed each year, sub-10% holdings can be caught by the FIF deemed-return rules, and IR458 is due annually. Get a written CFC and FIF read of the cap table before you incorporate, not after.

4. Working for the company from a NZ home office. Habitually negotiating and signing contracts for the Singapore company from New Zealand can give it a permanent establishment there, which makes the linked profit taxable in New Zealand, treaty or not.

5. Moving IP or shares out of the NZ company on your own. Shifting assets to the new Singapore entity has valuation and tax consequences in New Zealand. Price any intercompany fees, licences or loans at arm's length, and get NZ advice before moving anything of value.

Frequently asked questions

Does keeping my house in New Zealand keep me NZ tax resident?

It can. New Zealand treats you as resident while you have a permanent place of abode there, and a home that stays available to you can count even if you spend most of the year in Singapore.

If I set up a Singapore company but stay in New Zealand, do I still pay NZ tax?

Yes, in part. The company is a controlled foreign company for NZ purposes: active profits kept in it are generally not taxed in NZ until distributed, passive income above the 5% threshold is attributed each year, and every dividend is taxed at your marginal rate with no imputation credit.

Is there withholding tax on dividends paid by a Singapore company to New Zealand?

No. Singapore's one-tier system charges no dividend withholding tax to any shareholder. The treaty's 5% and 15% caps matter only for dividends flowing from New Zealand to Singapore.

Does Singapore tax capital gains?

Not as a general rule. Selling shares you hold as an investment is normally tax-free, though IRAS can tax gains as income if you trade shares as a business. The narrow Section 10L rule also taxes gains on foreign assets received in Singapore by entities without adequate economic substance here.

What happens if I move back to New Zealand?

You become NZ-resident again and are taxed on worldwide income, Singapore dividends included. New Zealand's four-year transitional exemption on most foreign income only applies if you were not NZ tax resident at any time in the previous 10 years, and only once.

Set up your Singapore company with the numbers right

If you are a New Zealand founder weighing up the move, or already set up and wanting a team that understands the NZ questions, talk to us. As a corporate partner of the NZ Chamber of Commerce Singapore, we can also introduce you to the Kiwi business community here. See how our company incorporation service works, on a fixed monthly fee from S$300 with Xero included, or book a free consultation, no obligation.