Moving from Australia to NZ: Financial Guide for High-Net-Worth Migrants
Moving from Australia to New Zealand is physically easy — a three-hour flight, no visa required for NZ citizens and permanent residents under the trans-Tasman arrangement. The financial transition is more complex than most people expect, especially if you have significant assets. Australian CGT rules follow you out the door, superannuation has specific portability rules, and your SMSF becomes a compliance headache the moment you leave.
This guide covers the financial considerations specific to Australians (or Australian tax residents) with meaningful wealth who are moving to NZ. For the general "moving to NZ" setup (bank accounts, IRD numbers, KiwiSaver), see our Moving to NZ financial guide.
Capital gains tax: CGT event I1
When you cease being an Australian tax resident, the ATO treats you as having sold and repurchased all your CGT assets at market value on your last day of Australian tax residency. This is CGT event I1 — a deemed disposal.
What this means in practice:
- Every asset you hold (shares, investment property, business interests, collectibles) is assessed as if you sold it on the day you leave
- Any unrealised capital gain is crystallised and becomes taxable in your final Australian tax return
- The 50% CGT discount applies if you've held the assets for 12+ months
Exception: Australian real property. If you keep Australian real estate (residential or commercial), you can choose to defer CGT event I1 for those properties. They remain subject to Australian CGT when you eventually sell them — but note that non-residents lose the 50% CGT discount for any gains accruing after 8 May 2012.
Practical step: Get a professional valuation of all CGT assets before you leave Australia. You need the market value on your departure date, and "I think it was worth about..." doesn't satisfy the ATO.
Superannuation transfers
Under the trans-Tasman portability arrangement, you can transfer your Australian superannuation balance to a NZ KiwiSaver scheme. Key points:
- The transfer is voluntary — you can leave your super in Australia if you prefer
- Transferred funds are locked in KiwiSaver until NZ retirement age (65), just as they would be locked in super until Australian preservation age
- The transferred amount keeps its "Australian super" character for NZ tax purposes — it's not treated as a new KiwiSaver contribution
- You cannot transfer from KiwiSaver back to Australian super (it's one-way)
Should you transfer? The answer depends on fund performance, fees, and your long-term plans. If you might return to Australia, leaving your super in place avoids the hassle. If you're permanently relocating, consolidating into KiwiSaver simplifies your financial life but means you're locked into NZ's retirement framework.
Australian super funds generally have wider investment options and lower fees than NZ KiwiSaver schemes (due to Australia's larger market). This is a practical factor worth weighing.
SMSF complications
If you have a Self-Managed Super Fund (SMSF), leaving Australia creates specific problems:
- Central management and control test: The ATO requires an SMSF's central management and control to be in Australia. If you (as trustee) move to NZ, the fund may fail this test and lose its complying status — resulting in the entire balance being taxed at the top marginal rate (45% + Medicare levy)
- Active member test: If you're the only member (or all members leave Australia), the fund fails the active member test for residency after 2 years of absence
- Contributions: You generally can't make contributions to an SMSF from overseas employment income
Options:
- Wind up the SMSF before you leave and roll into a retail/industry super fund
- Appoint an Australian-resident trustee or corporate trustee to maintain central management
- Transfer to KiwiSaver under the portability arrangement (only after rolling out of SMSF into a standard fund first)
Option 1 is the cleanest for a permanent move. Option 2 works if you want to keep the SMSF structure, but adds ongoing compliance costs and trustee obligations.
The Australia-NZ double tax agreement
The DTA between Australia and NZ prevents double taxation on most income types. Key provisions for migrants:
- Salary/wages: Taxed only in the country where the work is performed. If you work in NZ, NZ taxes it. Australian salary from before your move is taxed in Australia only.
- Dividends: Australian franked dividends paid to NZ residents are taxed in NZ. Franking credits have no value in NZ — the franking credit system is purely Australian.
- Interest: Generally taxed in the country of residence (NZ after you move), with a 10% withholding in the source country.
- Capital gains on real property: Taxed in the country where the property is located. Australian investment property gains remain subject to Australian CGT.
- Pensions/annuities: Australian super pension payments to NZ residents are taxable in NZ.
Franking credits: This is the biggest surprise for Australian investors. NZ does not recognise Australian franking (imputation) credits. When you receive a fully franked dividend from an Australian company as a NZ resident, you pay NZ tax on the gross dividend amount. You do get a foreign tax credit for any Australian withholding tax, but the franking credits themselves are worthless to a NZ tax resident.
NZ tax differences that affect Australians
| Feature | Australia | New Zealand |
|---|---|---|
| Capital gains tax | Yes — broad CGT with 50% discount | No general CGT (except bright-line for property, FIF for foreign funds) |
| Negative gearing | Allowed on investment property | Allowed but limited (ring-fencing of rental losses) |
| Imputation credits | Franking credits reduce personal tax | No franking credits — NZ uses a different imputation system |
| Retirement age | Preservation age 60 (moving to 67 for state pension) | KiwiSaver access at 65 |
| GST rate | 10% | 15% |
| Top income tax rate | 45% (+ 2% Medicare levy) | 39% (from $180,001) |
| Stamp duty on property | Yes (varies by state) | No stamp duty |
| ACC (accident cover) | No equivalent levy | ~1.45% levy on earnings |
Transferring money
For large transfers (NZD $500,000+), use a foreign exchange broker rather than a bank-to-bank transfer. Specialist FX providers typically offer exchange rates 1-3% better than the big banks, which on a $5M transfer could save $50,000 to $150,000.
Timing: The AUD/NZD rate fluctuates. If you're transferring a large sum, consider staging the transfer over several weeks or months to average out exchange rate movements, rather than converting everything on a single day.
Transitional resident exemption
As a new NZ tax resident (assuming you haven't been one in the past 10 years), you qualify for the transitional resident tax exemption — a 4-year exemption on most foreign-sourced income. This means Australian dividends, interest, and investment income (other than employment income) can be received tax-free in NZ during the transitional period.
This creates a planning window: any foreign income you receive in the first 4 years of NZ residency is potentially exempt from NZ tax. Coordinate with your Australian tax obligations to minimise the total tax burden across both countries.
Related guides
- Active Investor Plus Visa: Complete Guide — if you're applying for the AIP visa
- Transitional Resident Tax Exemption — 4-year foreign income exemption
- Moving to NZ: Financial Guide — practical setup for all new residents
- NZ Tax Residency Rules — how the 183-day and permanent place of abode tests work
- KiwiSaver Projection — model your KiwiSaver balance at 65
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This is educational content, not financial advice.