By Joe Sothcott, Young Jin Kim & Annamaria Maclean


With the Pillar Two rules now in force in New Zealand and as we edge closer to the first registration deadlines, we take a look at the common queries and questions we have received about how the Pillar Two rules work in New Zealand (Note: answers are accurate as at August 2025).

Have the Pillar Two rules been enacted in New Zealand?

Yes – the New Zealand Government enacted legislation to formally implement the OECD Global Anti-Base Erosion (GloBE) Pillar Two rules in March 2024. The new Pillar Two rules will apply to multinational enterprise groups (MNE groups) with global turnover above EUR750m in two of the four preceding income years.

In addition to the 20 to 25 New Zealand-headquartered groups on Inland Revenue’s radar, the Pillar Two rules will apply to inbound groups operating in New Zealand (e.g., via a subsidiary, branch or permanent establishment) that group meet the global turnover threshold of EUR750m.

The GloBE rules, as enacted in New Zealand, include:


The Income Inclusion Rule (IIR) and Under Taxed Profits Rule (UTPR) that will apply to both New Zealand-headquartered groups and inbound groups for income years beginning on or after 1 January 2025
The Domestic Income Inclusion Rule (DIIR) will apply for income years beginning on or after 1 January 2026.

The Qualified Domestic Minimum Top-up Tax (QDMTT) has not been enacted in New Zealand.

Please refer to our previous Tax Alert articles on Pillar Two for an overview of the GloBE rules and our comments on the recommended next steps that groups should take to understand their exposure to these rules. 

New Zealand registration requirements

New Zealand constituent entities are required to register in New Zealand six months after the end of the first fiscal year they are in scope of the GloBE rules. For example, for an entity with a fiscal year end of 31 December, the registration due date is 30 June 2026 (being six months after the end of the first year the rules apply – 1 January 2025). This also means 30 June 2026 is the earliest possible registration deadline. This applies to both New Zealand headquartered MNEs and groups with a subsidiary, branch or permanent establishment in New Zealand. Failure to register could result in a penalty of up to NZD100,000.

At this stage, it seems likely that pillar two registrations will be administered electronically via the myIR system, but as of early August 2025 it is unclear what the format of the registration will look like and the information that will need to be disclosed as part of this process (so unfortunately you can’t go and get this task ticked off now as you’re reading this article). It is also unclear whether Pillar Two registrations will be required for each constituent entity in New Zealand, or a nominated entity can register on behalf of all New Zealand constituent entities that are part of the same MNE group.

Based on the limited information released by Inland Revenue in the May 2024 Tax Information Bulletin, we expect the registration form will require disclosure of the identity and location of the designated filing entity for the MNE group that will be filing the GloBE Information Return (GIR) and contact details of the New Zealand constituent entity. This information will notify Inland Revenue of the country from which the GIR will be received – either New Zealand or another country through information exchange – and will provide a point of contact if the GIR is not received.  

Annual Multinational top-up tax return

Based on the Pillar Two legislation that has been passed, each New Zealand constituent entity is expected to be required to file an annual multinational top-up tax return (MTTR) even if there is no top-up tax liability.

The return must be filed within 16 months of the last day of the relevant fiscal year or 20 months for the first year of application. For example, if a New Zealand constituent entity has a 31 December balance date and is first subject to the GloBE rules in the 2025 fiscal year, their first MTTR will be due on 31 August 2027 (20 months after 31 December 2025). Their second MTTR will be due on 30 April 2028 (16 months after 31 December 2026). Payment of any multinational top-up tax would also be due on the same day the MTTR is due to be filed with Inland Revenue.

Again, it is unclear whether a separate MTTR will be required for each constituent entity in New Zealand or a nominated entity can file a single MTTR on behalf of all New Zealand constituent entities that are part of the same MNE group.

As with the registration requirements, Inland Revenue is yet to release the format of the New Zealand MTTR. However, we understand it will be required to disclose the following:


Whether or not the New Zealand constituent entity has a multinational top-up tax liability for the fiscal year
The amount of multinational top-up tax payable by the New Zealand constituent entity for the fiscal year (if any) and
Any other information required by the Commissioner (no further information has been provided in relation to this).

GloBE Information Return

The GloBE Information Return (GIR) must be filed in New Zealand within 15 months from the last day of the relevant fiscal year. This is extended to 18 months for the first year of application. For example, if a New Zealand constituent entity has a December balance date and is first subject to the GloBE rules in the 2025 fiscal year, their first GIR will be due on 30 June 2027 (18 months after 31 December 2025). Their second GIR will be due on 31 March 2028 (15 months after 31 December 2026).  Care will need to be taken on the timing if the multinational group is subject to the GloBE rules in another country in an earlier year.

The GIR does not need to be filed in New Zealand where it is filed on time by the Ultimate Parent Entity or Designated Filing Entity located in a jurisdiction that has a Qualifying Competent Authority Agreement with New Zealand. A Qualifying Competent Authority Agreement is a bilateral or multilateral agreement between Competent Authorities that allows for automatic exchange of information. This limits the compliance burden on MNE Groups by limiting the number of jurisdictions where the GIR is required to be filed.

The above exception does not apply to New Zealand headquartered MNE groups and Inland Revenue requires the GIR to be filed in New Zealand for income years beginning on or after 1 January 2025.  

GIRs that are filed in New Zealand will follow the standard template that has been developed by the OECD.

Does New Zealand have a Qualified Domestic Minimum Top-up Tax?

New Zealand has not implemented a QDMTT for foreign owned subsidiaries operating in New Zealand.

However, New Zealand has implemented a DIIR with effect from 1 January 2026. New Zealand’s DIIR functions like a QDMTT but only applies to New Zealand headquartered groups. The DIIR means New Zealand-headquartered groups do not have to pay any top-up tax on undertaxed New Zealand income (if there were any) to other countries under the UTPR.

 

If you have any questions, please contact your usual Deloitte advisor.