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01 Nov 2023

Directors' fees

The Commissioner has published several items on Directors’ fees. This overview sets out these items, organised by tax type and subject.

Goods and Services tax

Income tax

The Commissioner issues different types of guidance items to cater for different customer needs.  The different types of items are explained here.


Goods and services tax

Directors' fees and Board members' fees

Title Summary Date issued

GST – Directors’ fees and board members' fees

BR Pub 23/01 - 23/03 and Fact sheet

These Rulings (and accompanying Fact sheet) explain whether directors' fees and board members' fees are subject to GST.

Applies from 1 April 2023.
22 Feb 2023

Professional directors and board members incorrectly registered for GST

OP 23/02
This OP gives guidance on how BR Pub 23/01 -23/03 will be applied. Specifically, it explains the approach the Commissioner will take if a professional director or board member incorrectly registers for GST. 1 Sept 2023

GST - Directors and board members providing services through a personal services company

QB 23/07

This QWBA considers the GST treatment of a director or board member who provides their services through a personal services company. 21 Jul 2023 


Income tax

Timing - derivation of income from professional services

Title Summary Date issued

When is income from professional services derived?

IS 16/06

This IS provides guidance on when income from professional services should be returned for tax purposes. It also addresses the consequences of changing between the cash basis and the accrual basis. 20 Dec 2016

Excessive remuneration

Title Summary Date issued

Meaning of 'excessive remuneration' and 'excessive profits or losses'

QB 14/09

This QWBA considers when the payment of remuneration or allocation of profits or losses are considered to be excessive for the purposes of ss GB 23 to GB 25B. It considers the meaning of excessive remuneration and excessive profits or losses when paid or allocated to relatives, partners, shareholders or directors. 21 Aug 2014

Schedular payment rules

Title Summary Date issued

Schedular payment rules and directors’ fees

IS 17/06

This IS discusses how the schedular payment rules apply to payments of directors’ fees. In particular, it discusses when tax must be withheld from directors’ fee payments and how much tax must be withheld if withholding is required. 18 Jul 2017

Schedular payment rules and non-resident directors' fees

IS 19/01

This IS considers when tax must be withheld from directors’ fees paid to non-residents, and discusses when directors’ fees paid to non-residents are considered to have a New Zealand source. It also considers how much tax must be withheld, if withholding is required. 28 Feb 2019
Commissioner's operational position on how schedular payment rules apply to non-resident directors' fees  This OP reviews how schedular payment rules apply to non-resident directors' fees on income tax. 28 Feb 2019