2006 addition of Spain to the grey list – a list of countries whose tax systems are broadly similar to NZ.

Schedule 3 of the Income Tax Act 2004

The grey list is a list of countries whose tax systems are broadly similar to that of New Zealand's. Investments made in grey list countries are generally not subject to the controlled foreign company (CFC) and foreign investment fund (FIF) rules.

Key features

Spain has been added to the grey list via an amendment to Schedule 3 of the Income Tax Act 2004.

Investments in Spain are not eligible for the grey list exemption if any CFC or FIF takes advantage of concessionary tax regimes in the following regions:

  • Canary Islands
  • Ceuta
  • Melilla
  • Alava
  • Guipuzcoa
  • Vizcaya, or
  • Navarra.

Application date

The amendment applies for income years corresponding to the 2006 - 07 and subsequent tax years.