Tax Administration (Deemed Rate of Return on Attributing Interests in Foreign Investment Funds, 2025–26 Income Year) Determination 2026
This determination sets the deemed rate of return, used to calculate foreign investment fund income under the deemed rate of return calculation method, for the 2025-26 income year at 7.84%. The deemed rate of return set for the 2024-25 income year was 8.04%.
Tax Administration (Deemed Rate of Return on Attributing Interests in Foreign Investment Funds, 2025–26 Income Year) Determination 2026
This determination is made under section 91AAP of the Tax Administration Act 1994 by the Commissioner of Inland Revenue.
Determination
1. Title
This determination is the Tax Administration (Deemed Rate of Return on Attributing Interests in Foreign Investment Funds, 2025–26 Income Year) Determination 2026.
2. Commencement
This determination comes into force on 30 April 2026.
3. Deemed rate of return on attributing interests in foreign investment funds for 2025–26 income year
The deemed rate of return applying for the 2025–26 income year for the purposes of sections EX 55(4)(b) and EX 55(6)(c) of the Income Tax Act 2007 is 7.84%.
This determination was made in Christchurch on the 23rd day of April 2026.
Stephen Donaldson
Technical Lead
Inland Revenue
Explanatory Note
This note is not part of the determination but is intended to indicate its general effect.
This determination sets, for the 2025–26 income year, the deemed rate of return used to calculate foreign investment fund income under the deemed rate of return calculation method set out in section EX 55 of the Income Tax Act 2007.
This determination sets the deemed rate of return for the 2025–26 income year at 7.84%. The deemed rate of return set for the 2024–25 income year was 8.04%.
Legislative information
This instrument is secondary legislation issued under the authority of the Legislation Act 2019.
| Field name | Information |
|---|---|
| Title | Tax Administration (Deemed Rate of Return on Attributing Interests in Foreign Investment Funds, 2025–26 Income Year) Determination 2026 |
| Principal or amendment | Principal |
| Consolidated version | No |
| Empowering Act and provisions | Tax Administration Act 1994 section 91AAP |
| Replacement empowering Act and provisions | Not applicable |
| Maker name | The Commissioner of Inland Revenue |
| Administering agency | Inland Revenue Department |
| Date made | 23 April 2026 |
| Publication date | 29 April 2026 |
| Notification date | Not applicable |
| Commencement date | 30 April 2026 |
| End date | Not applicable |
| Consolidation as at date | Not applicable |