Leaving New Zealand for Dubai turns on the home you keep

A gentle exit with one hard test

New Zealand lets a founder leave more cleanly than Australia or the Nordic countries, and the one place it is strict is the question of whether you have really gone. There is no exit tax, so nothing is charged on the way out. There is no general capital gains tax, so the shares in the company you built do not face a departure bill. Set beside an Australian departure, which deems your assets sold on the day you leave, or a Norwegian one, which taxes the unrealised gain, the New Zealand exit is unusually light.

The catch is not a charge. It is a definition. New Zealand decides whether you are still its tax resident by looking at the home you keep, and a founder who moves to Dubai while leaving a house available in Auckland can remain a New Zealand tax resident, taxed on worldwide income, for as long as that house is there. The move abroad does not end the tax on its own. Giving up the home does.

This note takes the New Zealand side of the move in order: how residence actually ends, why the exit is light on tax, the treaty that New Zealand has with the UAE and Australia does not, the company left behind, and the KiwiSaver that can follow you. It is written for a founder or business owner relocating to the UAE, and it reads most usefully alongside the companion note on the Australian version of the same move, because the contrast between the two is instructive.

New Zealand decides you have left by the home you keep

New Zealand tax residence ends only when you both lose your permanent place of abode in the country and stay away long enough, and the home is the harder of the two conditions. Under section YD 1 of the Income Tax Act 2007 you are a New Zealand tax resident if you have a permanent place of abode here, whatever your day count, or if you are present for more than 183 days in a 12-month period.

Residence ends under the 325-day rule only when you have been absent for more than 325 days in a 12-month period and no longer have a permanent place of abode in New Zealand.

The permanent place of abode is the test that catches people, because it overrides the day count. A permanent place of abode is a dwelling you could live in, considered together with the ties that bind you to it, your family, your business connections, your personal property and the pattern of your life. A holiday house used occasionally is usually not one. A family home kept available, or a house let on a short lease that you could reoccupy, often is. Inland Revenue's view of how the tests work is set out in its 2025 interpretation statement IS 25/16.

The practical effect is sharp. If you move to Dubai but keep a house in New Zealand that remains available to you, you can stay a New Zealand tax resident even after a full year away, and New Zealand will continue to tax your worldwide income. The 325 days are only the gate. The home is the lock.

When residence does end, it is backdated. You are treated as non-resident from the later of the first of the 325 days of absence or the day after you last had a permanent place of abode here. That makes the date you genuinely give up the home the date that matters, so it is worth being able to show when the home ceased to be available.

There is no exit tax and no general capital gains tax

Leaving New Zealand does not trigger a tax on the way out, because the country has neither an exit tax nor a general capital gains tax. Nothing in New Zealand law treats your shares as sold when you cease to be resident, and there is no standing tax on capital gains to catch the sale of the company after you have gone. This is the quiet advantage of the New Zealand exit, and it is a real one for a founder sitting on years of growth in a private company.

The main exception is residential property. The bright-line property rule taxes the gain on residential land sold within two years of acquiring it, for sales on or after 1 July 2024, treating the gain as income rather than as a capital gain. It reaches a New Zealand tax resident's overseas residential property as well as New Zealand land, so a Dubai apartment bought by someone who is still a New Zealand resident can be within it. A property that has been your main home for more than half of the period you owned it is generally excluded, and business premises and farmland sit outside the rule.

Two further points are worth keeping in view rather than treating as settled. New Zealand taxes some holdings of foreign shares on an accrual basis under the foreign investment fund rules, which can matter to an investment portfolio but rarely to a founder's stake in their own trading company. And a sale of shares can still be taxed where it amounts to a profit-making activity rather than a passive disposal. Neither of these is a general capital gains tax, and for most owner-managed businesses the plain position holds: the departure itself is not taxed.

The contrast with the other corridor exits is the point. An Australian founder faces a deemed disposal on departure, and a Norwegian, Swedish or Danish founder faces an exit tax or a long tail, as set out in the notes on the Australian departure and the Nordic exit taxes. A New Zealander faces none of those, which makes the residence question, not the tax charge, the thing to get right.

A treaty with the UAE, which Australia does not have

New Zealand has a double tax agreement with the UAE, and that single fact separates a New Zealand move from an Australian one. The agreement entered into force in 2004 and took effect for New Zealand withholding taxes from 1 September 2004 and for other taxes from the income year beginning 1 April 2005. Australia, by contrast, has no tax treaty with the UAE at all, which is the hinge of the Australian version of this move.

What the treaty gives is a framework and a tie-breaker. If you are briefly resident in both countries during the transition, the treaty's residence article decides which country may treat you as resident, so you are not left exposed to two unrelieved domestic systems at once. It also allocates taxing rights over categories of income between the two states and sets the basis on which each gives relief.

What the treaty does not do is override New Zealand's own residence test. If you keep a permanent place of abode in New Zealand, you remain a New Zealand resident under domestic law, and the treaty's tie-breaker only engages if the UAE also treats you as resident under its rules. Because the UAE imposes no personal income tax, the treaty rarely has to resolve a genuine double charge on an individual. Its value is in giving the move a settled legal footing and in the certainty it brings to the company and investment income that crosses between the two countries, rather than in cancelling a New Zealand liability that the home test has already fixed.

A UAE tax residency certificate helps here. Obtained under Cabinet Decision No. 85 of 2022, it evidences that your life has moved to the UAE, which supports both the loss of your New Zealand permanent place of abode and any treaty position. The tests behind it are set out in the note on the UAE's 90-day and 183-day residence rules.

The company you leave behind stays a New Zealand company

A New Zealand company does not stop being a New Zealand taxpayer when its owner moves to Dubai, because it is resident where it was incorporated. Under section YD 2 of the Income Tax Act 2007 a company is a New Zealand tax resident if it is incorporated here, or if it has its head office, its centre of management, or control by its directors in New Zealand. The incorporation test alone keeps a New Zealand company resident wherever its shareholder goes, so the business carries on paying New Zealand company tax after the founder has left.

Forming a UAE company instead does not solve this while you are still a New Zealand resident. New Zealand's controlled foreign company rules can attribute the income of a company you control abroad back to you while you remain resident, so a UAE company set up before your residence has genuinely ended can be taxed in your hands in New Zealand. The attribution turns on the kind of income the company earns and the degree of your control.

Residence of the UAE company is the mirror risk. A company incorporated in the UAE can still be a New Zealand tax resident if its centre of management or its directors' control sits in New Zealand, so a UAE company run from Wellington during the transition is exposed to New Zealand residence in substance. The same doctrine, as it plays out across the corridor, is examined in the note on where a company is actually tax resident.

On its own side the UAE company is governed by UAE law from the day it is formed. It pays 9% corporate tax on taxable income above AED 375,000 under Federal Decree-Law No. 47 of 2022, unless it meets the conditions of the free zone regime, and it runs its own compliance calendar. The choice of zone and what it commits the company to is set out in the guide to choosing a UAE free zone, the real cost over the first years in the structure of UAE set-up costs, and the first year's filings in the first-year compliance calendar.

KiwiSaver can come with you, after a year

KiwiSaver is one thing a New Zealand founder can usually take to Dubai, which is not true of Australian superannuation. After you have permanently emigrated to a country other than Australia and a year has passed, you can withdraw most of your KiwiSaver savings, including your own contributions, your employer's contributions, any kickstart you received and the interest earned. The one part you cannot take is the government contributions, which are returned to Inland Revenue.

This is a genuine difference from the Australian position, where an Australian citizen or permanent resident cannot access their superannuation on leaving and must wait until a normal condition of release is met. A New Zealander moving to the UAE can, after the one-year wait, bring the KiwiSaver balance across and deploy it, which is worth building into the timing of the move rather than discovering afterwards.

The move to Australia is the exception within the exception. KiwiSaver cannot be withdrawn on emigration to Australia, because a separate trans-Tasman arrangement lets it be transferred into an Australian complying fund instead. For a move to Dubai, the straightforward one-year withdrawal is the relevant route.

New Zealand and Australia side by side

The table sets the two Antipodean exits against each other, because a founder choosing between them, or comparing a New Zealand move with the Australian note, is served by seeing the difference in one place.

Read across the rows and New Zealand is the lighter departure on almost every line. The one row that is not lighter is the first, because the permanent place of abode test can keep a New Zealander resident long after an Australian on the same facts would have left.

The order that works

The sequence that keeps a New Zealand move clean is to settle residence first, because almost nothing else is taxed on the way out and the residence question is the one that lingers. The order is short.

1. Decide what happens to any New Zealand home, because keeping one available can hold your residence open however long you are in Dubai.
2. Fix the date your permanent place of abode genuinely ends, and keep evidence of it, since residence is backdated to that date.
3. Check the bright-line position on any residential property, in New Zealand or abroad, bought within the last two years.
4. Decide what happens to the New Zealand company and how its profits reach you, with the controlled foreign company rules in mind if a UAE company is formed early.
5. Plan the KiwiSaver withdrawal around the one-year wait, and build the UAE side, the licence, the owner's visa and then the family's, and the bank account, to the same timetable.

The founders whose moves run cleanly are the ones who treated the home, not the flight, as the thing that ended their New Zealand tax residence, and who could show exactly when it ended.

Frequently asked questions

Do I stop being a New Zealand tax resident as soon as I move to Dubai?

Not necessarily. New Zealand residence ends only when you are both absent for more than 325 days in a 12-month period and no longer have a permanent place of abode in New Zealand, under section YD 1 of the Income Tax Act 2007. The permanent place of abode is decisive: if you keep a home available here, with the ties that go with it, you can remain a New Zealand tax resident even after a year in Dubai, and New Zealand will keep taxing your worldwide income. Moving abroad starts the day count, but giving up the home is what actually ends your residence.

Does New Zealand have a capital gains tax or an exit tax?

No, New Zealand has neither a general capital gains tax nor an exit tax. Leaving does not deem your assets sold, and there is no standing tax on capital gains to catch the later sale of your company. The main exception is the bright-line property rule, which taxes the gain on residential property sold within two years of buying it, treating it as income, and which also reaches a New Zealand resident's overseas residential property. For most founders leaving with shares in their own trading company, the departure itself carries no New Zealand tax.

Is there a tax treaty between New Zealand and the UAE?

Yes. The New Zealand-UAE double tax agreement entered into force in 2004 and took effect for New Zealand withholding taxes from 1 September 2004 and for other taxes from the income year beginning 1 April 2005. This is a clear difference from Australia, which has no tax treaty with the UAE. The treaty provides a residence tie-breaker if you are briefly resident in both countries and allocates taxing rights over income between them, but it does not override New Zealand's domestic residence test, so keeping a permanent place of abode here still makes you resident regardless of the treaty.

What is a permanent place of abode in New Zealand?

It is a dwelling in New Zealand that you could live in, judged together with the ties that connect you to it. Inland Revenue looks at whether a home is available to you and at the surrounding connections, your family, your business interests, your personal belongings and the overall pattern of your life. A holiday house used occasionally is generally not a permanent place of abode. A family home kept available, or a house let on terms that let you reoccupy it, often is. Because this test overrides the day count, it is usually the deciding factor in whether a New Zealander has genuinely left.

Can I keep my New Zealand company after moving to Dubai?

Yes, but it stays a New Zealand company. Under section YD 2 of the Income Tax Act 2007 a company incorporated in New Zealand is a New Zealand tax resident wherever its owner lives, so it keeps paying New Zealand company tax after you move. Setting up a UAE company instead does not avoid New Zealand tax while you are still resident, because the controlled foreign company rules can attribute its income back to you, and a UAE company managed from New Zealand can itself be New Zealand resident through its centre of management or director control.

What happens to my KiwiSaver if I move to Dubai?

You can take most of it with you after a year. Once you have permanently emigrated to a country other than Australia and 12 months have passed, you can withdraw your own contributions, your employer's contributions, any kickstart and the interest earned, under the KiwiSaver rules. The government contributions are the exception and are repaid to Inland Revenue. This is unlike Australian superannuation, which stays locked for citizens and permanent residents who leave, so the KiwiSaver withdrawal is worth planning into the timing of your move.

Does a UAE tax residency certificate end my New Zealand residence?

No, but it helps. A UAE tax residency certificate confirms that you meet the UAE's own residence tests under Cabinet Decision No. 85 of 2022, and it is useful evidence that your life has moved, which supports the loss of your New Zealand permanent place of abode and any treaty position. It does not by itself end New Zealand residence, because that turns on whether you still have a home available here. The certificate strengthens your case rather than deciding it.

How is a move to Dubai from New Zealand different from one from Australia?

New Zealand is the lighter exit. New Zealand has no exit tax, no general capital gains tax and a tax treaty with the UAE, while Australia deems your assets sold on departure under CGT event I1, taxes capital gains and has no UAE treaty. The one area where New Zealand is not lighter is residence itself, because its permanent place of abode test can keep you resident while a home is available, whereas Australia weighs a wider set of factors. The companion note on the Australian departure sets out that side in full.

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Critical advisory. New Zealand asks one hard question behind a gentle exit. Have you really left, or have you kept a home here.

The permanent place of abode decides it, not the day count, and a house kept available can leave you taxed in New Zealand while you live in Dubai. Settle that before you go.

Fixing the residence position, and building the UAE company, visas and banking around it, is work we handle in-house across the UAE, the United Kingdom and Ireland. This is general information, not advice on your own facts.