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Income Tax Act 2007

Income - Exempt income

CW 55BAB: Rebate of fees paid by FIF

You could also call this:

“Getting some money back from fees paid by your foreign investment fund”

When you have an interest in a foreign investment fund and it pays fees to someone else, you might get some of that money back as a rebate. You get this rebate from the person the fund paid the fees to. This happens when you are not allowed to claim the fees as a deduction and you do not use the comparative value method to work out your income or loss from the fund.

The amount of money you get back as a rebate is considered exempt income, which means you do not have to pay tax on it. You can find more information about how this law was changed by looking at the Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Act 2014 and the Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025. This law applies to you if you meet the conditions and have an attributing interest in a foreign investment fund.

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View the original legislation for this page at https://legislation.govt.nz/act/public/1986/0120/latest/link.aspx?id=DLM5968505.

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Part C Income
Exempt income

CW 55BABRebate of fees paid by FIF

  1. This section applies to a person having an attributing interest in a foreign investment fund when—

  2. the FIF pays fees to another person; and
    1. the person derives, from the other person, a rebate of the fees; and
      1. the person is not allowed a deduction for the fees; and
        1. the person's FIF income or loss from the interest is not calculated using the comparative value method.

          1. The amount of the rebate is exempt income.

          Notes
          • Section CW 55BAB: inserted (with effect on 1 April 2009), on , by section 20(1) of the Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Act 2014 (2014 No 4).
          • Section CW 55BAB(2) heading: inserted, on , by section 30 of the Taxation (Annual Rates for 2024–25, Emergency Response, and Remedial Measures) Act 2025 (2025 No 9).