New Zealand: Exposure draft on portfolio investment entity income from land development
Public submissions on the draft decision close on April 15, 2026.
Inland Revenue on March 5, 2026, released a draft decision on whether income from land development activities qualifies as eligible income of a portfolio investment entity (PIE).
The draft concludes that income from developing land and disposing of subdivided land or buildings would generally fall within permitted PIE income under sections HM 11 and HM 12 of the Income Tax Act 2007.
The clarification is significant as PIE income is subject to a maximum tax rate of 28%, compared with the 39% top personal income tax rate.
Public submissions on the draft decision close on April 15, 2026.
For more information, contact a KPMG tax professional in New Zealand:
Rachel Piper | rkpiper@kpmg.co.nz
Sladja Lines | sladjalines@kpmg.co.nz