The New Zealand government has passed legislation – The Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Act – implementing the OECD’s Pillar Two rules. As EY observes: ‘The Income Inclusion Rule (IIR) and Under Taxed Profits Rule (UTPR) … apply from 1 January 2025. However, the Domestic Income Inclusion Rule (DIIR) will apply only to New Zealand-headquartered MNEs and is deferred to 1 January 2026. This limited scope distinguishes the DIIR from a Qualifying Domestic Minimum Top-up Tax (QDMTT), as defined by the OECD.’
The New Zealand government has passed legislation – The Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Act – implementing the OECD’s Pillar Two rules. As EY observes: ‘The Income Inclusion Rule (IIR) and Under Taxed Profits Rule (UTPR) … apply from 1 January 2025. However, the Domestic Income Inclusion Rule (DIIR) will apply only to New Zealand-headquartered MNEs and is deferred to 1 January 2026. This limited scope distinguishes the DIIR from a Qualifying Domestic Minimum Top-up Tax (QDMTT), as defined by the OECD.’
