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ARTICLE 1

U.S. Income Tax Treaty — New Zealand Income Tax Treaty - 1982 · 2026-10-03 edition · updated 2026-10-04 · United States

General Scope

  1. This Convention shall apply to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention.

  2. The Convention shall not restrict in any manner any exclusion, exemption, deduction, credit, or other allowance which may be accorded:

(a) by the law of either Contracting State; or (b) by any other agreement between the Contracting States.

  1. Notwithstanding any provision of the Convention except paragraph 4, a Contracting State may tax its residents (as determined under Article 4 (Residence)), and the United States may tax its citizens and United States companies, as if the Convention had not come into effect. For this purpose, the term "citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss.

  2. The provisions of paragraph 3 shall not affect:

(a) the benefits conferred in a Contracting State under the Convention in accordance with paragraph 2 of Article 9 (Associated Enterprises), paragraph 1(b) of Article 18 (Pensions and Annuities), and Articles 22 (Relief From Double Taxation), 23 (Non-discrimination), and 24 (Mutual Agreement Procedure); and

(b) the benefits conferred in a Contracting State under the Convention in accordance with Articles 19 (Government Service), 20 (Students), and 26 (Diplomatic Agents and Consular Officers), upon individuals who are neither citizens of, nor have immigrant status in, that State.

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▸Contents — U.S. Income Tax Treaty — New Zealand Income Tax Treaty - 1982
U.S. Income Tax Treaty — New Zealand Income Tax Treaty - 1982

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