DESIRING to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion in the field of taxation on income, 1. This Convention shall not affect the tax privileges of members of diplomatic missions or consular representations, in accordance with the general rules of international law or the provisions of specific agreements. If he is a national of both States or of one of the two States, the competent authorities of the States Parties shall decide by mutual agreement on the matter. 5. Where a person other than a natural person resides in both States Parties pursuant to paragraph 1 of this article, the competent authorities of the States Parties shall endeavour by mutual agreement to clarify the matter taking into account their place of effective administration, the place of their incorporation or any other composition and other relevant factors. In the absence of such an agreement, that person is not entitled to a tax reduction or exemption under the agreement. 5. The competent authorities of the Contracting States may, in cases not provided for in the Convention, consult each other on the elimination of double taxation and communicate directly with each other for the purposes of applying the Convention. If New Zealand were to include an article of non-discrimination in any of its double taxation conventions at any time after the date of its signature, discussions shall be held between The States Parties to determine whether to include an article of non-discrimination in this Convention. It is explained that the agreements set out in the list are agreements with the Government of Canada to provide an exemption from double taxation with respect to income tax and excess tax under the Income Tax Act 1976 and income taxes levied by the Government of Canada, without prejudice to income tax and surplus tax levied under the Act Immunizing this Act or any other decree in accordance with the tone of the Convention. The main feature of the agreement is the reduction of wht rates for dividends, royalties and interest payments. On 2 July 2015, New Zealand Finance Minister Todd McClay announced the entry into force of the New Zealand Double Taxation Convention (DBA) on 26 June 2015. The new DBA was signed on 3 May 2012 and the protocol thereto on 12 September 2014.
The new DBA replaces the 1980 contract.