Executive Summary

AIP offers world-class backup-plan visas to optionality seekers.
 TRE converts them to tax-paying full-time residents.

Under Immigration Minister Erica Stanford’s leadership, the Active Investor Plus visa (AIP) has become, by any objective measure, the best-designed golden visa programme on the planet. It was built with genuine sophistication for the market that existed when it was conceived: wealthy international families seeking backup-plan residency optionality in a safe, stable, English-speaking jurisdiction. It has attracted 1,833 applicants with NZD 3.39 billion in committed investment capital into a government pipeline that no other programme of its kind can match.

But the world has changed dramatically since AIP was designed. Where it was once assumed that persuading ultra-high-net-worth families to leave their birth countries and move to the end of the earth was an unrealistic goal, the geopolitical upheaval of 2022–2026 has made that a generational opportunity. The families AIP was designed to reach are no longer content with a backup plan. They want a stable permanent home. And they’re ready to relocate internationally to get one. Thanks to AIP’s architects, the pipeline is already built. What is missing is the post-transitional tax architecture that converts that pipeline of optionality seekers into committed, tax-paying, permanently settled New Zealand residents.

AIP gets wealthy households to New Zealand’s front door. But that door is locked shut by our post-transitional tax settings. Every major New Zealand advisory firm—KPMG, Deloitte, Simpson Grierson, Russell McVeagh, MinterEllison, PwC, EY, BDO, CAANZ, and the NZ Law Society—gives the same advice to ultra-high net worth clients: do not establish tax residency in New Zealand, or plan to leave before Month 49. This is not one firm’s opinion. It is the unanimous professional consensus of every major advisory practice in the country.

For the first time in history, the world’s wealthiest families are actively leaving their birth countries.

More than 26,000 millionaires moved to Dubai in the three years to 2025, including 9,800 in 2025 alone. They chose Dubai for its tax settings. Then, on 28 February 2026, Iran struck the United Arab Emirates with 167 ballistic missiles and over 500 drones. The Burj Al Arab was damaged. Every one of those households is now reconsidering. Where they relocate next is being decided now, this quarter. Meanwhile, in London, 57,500 former non-domiciled residents are inside the UK’s four-year Foreign Income and Gains countdown, choosing a new permanent home within 24–36 months.

One data point deserves specific ministerial attention: Germany has emerged as a top-four source country for AIP applications—without any New Zealand marketing effort there, without a cultural or language connection, and without any historical Commonwealth tie. Millionaire enquiries from Germany for alternative residence visas rose 114% between 2023 and 2024. In 2025, Germany recorded its first-ever net loss of millionaires. These households found AIP—a testament to the programme’s international visibility. But they have not found a post-transitional tax architecture that makes permanent settlement rational. AIP gave them the option to come to New Zealand despite our unwelcoming tax settings. TRE converts that option into an immediate and compelling reason to make New Zealand their permanent home.

UHNWI households make domicile decisions in two stages. New Zealand fails the first and never reaches the second:

The Government’s ongoing reform of the Foreign Investment Fund (FIF) regime is welcome and should be enacted. But for the ultra-high-net-worth household whose wealth spans private equity, offshore trusts, derivatives, and operating businesses across multiple jurisdictions, FIF reform repairs one wall of a house that needs a new foundation.

The day after FIF reform becomes law, the advice of the international wealth advisory community will be unchanged: UHNWI households should not come to New Zealand at all, or they should plan to leave before Month 49 if they do. FIF is one of six parallel compliance tracks. Fixing one does not fix the other five.

We just need to extend it.

The Transitional Residency Extension (TRE) is not a novel policy invention. New Zealand’s transitional tax residency has been part of our tax law for twenty years (effective 1 April 2006). It is already OECD-blessed—the OECD’s own June 2024 policy brief (Migration Policy Debates #35) catalogued New Zealand’s transitional residence alongside Italy, Denmark, and Korea as a legitimate policy tool. TRE simply proposes charging a flat fee and requiring larger investment in our productive economy to extend that existing mechanism beyond its current four-year window. This is a very small settings adjustment to an existing, proven, OECD-compatible policy—not a new programme. But that very small settings change will cause a massive change in behavior of the world’s wealthiest families, moving New Zealand from “ruled out from consideration due to untenable tax settings” to “top of the short-list”.

TRE extends our current transitional tax residency system in exchange for a single annual flat-tax payment.

TRE does not ask participants to calculate their foreign-sourced income and apply a preferential rate. It removes the obligation to calculate altogether—for foreign-sourced income only. Every dollar of New Zealand-sourced income is still taxed at full prevailing rates. All six parallel compliance tracks are replaced with a single known annual payment, fixed by statute for 16 years.

Statutory grandfathering. No sophisticated UHNWI household will commit to a 16-year residency decision on the basis of policy revocable by a future Budget. Grandfathering must be enshrined in statute—explicit, unconditional, and non-retrospective. Grandfathering converts a policy into a contract.

Calibrated launch pricing with pre-announced escalation. TRE launches at NZD 600,000 per year—near parity with Italy’s €300,000—with no mandatory qualifying investment at launch. Pre-announced escalation to NZD 750,000–800,000 at first repricing introduces a NZD 5 million qualifying investment for new elections only; existing participants are grandfathered. The pre-announcement creates an incentive to elect at launch pricing, and it signals to the market that the programme is designed for growth.

The Qualifying Growth Investment incentive (QGI). Participants may voluntarily deploy additional capital into qualifying New Zealand productive assets. For every additional investment tranche, the participant’s annual contribution reduces by 10%. A participant who invests NZD 100 million and earns a 25% return pays zero TRE contribution but generates NZD 7–10 million annually in standard New Zealand income tax on the domestic returns alone—considerably more than the flat contribution ever asks. The QGI converts TRE from a revenue instrument into a capital deployment engine.

The US Track. Americans constitute 40% of AIP applicants. The TRE US Track produces a substantially equivalent outcome via a Foreign Tax Credit-compatible deemed income formula. FTC compatibility is not peripheral. It is central to the programme’s largest source cohort.

The integrity architecture ensures the programme cannot be exploited: a qualifying offshore capital rule prevents round-tripping of NZ-origin wealth through offshore structures; source-of-funds verification mirrors existing AML/CFT standards; and clearly defined lapse conditions protect the Crown’s interest without creating the uncertainty that discourages participation.

It is flat tax vs zero.

The objection: “Surely the wealthiest can afford to pay more.” It is a reasonable intuition applied to the wrong question. The choice is not what rate to impose on UHNWI households that stay despite the current architecture. It is what to do about the vastly larger cohort that never comes at all—or that comes and leaves before Month 49—contributing nothing.

The United Kingdom ran this experiment at scale. When the UK abolished non-dom status and moved to a four-year Foreign Income and Gains window—structurally identical to New Zealand’s current settings—16,500 millionaires (22% of the pool) left within nine months. The UK effectively demonstrated what New Zealand’s present architecture produces: zero.

Historic Economic Opportunity for New Zealand

TRE converts global wealth migration into Crown revenue, capital investment, and tens of thousands of new jobs—enough to reverse the “brain drain”.

Not a single Kiwi’s tax changes. Every dollar is revenue that does not currently exist. The conservative scenario asks for fewer than half the number of millionaires who chose Dubai in a single year (9,800 in 2025), spread across an entire decade.

What NZD 4 billion annually means: approximately two new Dunedin-scale hospitals every year, or more than five times the annual school property investment in Budget 2025, or roughly 85 km of new four-lane motorway per year. The 2% scenario would exceed 60% of New Zealand’s entire corporate tax base (NZD 20.7B).

TRE Crown Revenue Projections — Three Market Penetration Scenarios vs. Status Quo

The red dashed line at the bottom is the status quo: the best FIF has ever produced (NZD 175 million peak). The blue line is TRE’s conservative scenario. The shaded area between them is revenue that cannot exist without TRE. Switzerland achieves NZD 1.76 billion annually from 4,557 participants in a programme operating since 1862—and that figure is TRE’s floor, not its ceiling.

AIP+TRE Projected Capital Investment — Three Market Penetration Scenarios

By Year 10, TRE’s mandatory qualifying investment alone channels tens of billions in cumulative capital into New Zealand’s productive economy—above and beyond any AIP visa investment. Using a conservative 25% participation rate in voluntary capital contribution through the Qualifying Growth Investment incentive, total investment would reach NZD 96–300 billion depending on the scenario. This is the capital that creates enterprises, generates employment, and gives the next generation of New Zealanders a reason to build their careers at home. The solution to the brain drain.

Tens of thousands of new jobs from foreign capital investment. An economy so strong the next generation of New Zealanders stays and builds here instead of leaving for Australia. Revenue to fund public services—without raising a single Kiwi’s tax by one cent.

No competitor can replicate New Zealand’s geopolitical safe-haven premium.

The UBS Billionaire Ambitions Report 2025 found that geopolitical concerns (36%) and tax efficiency (35%) are now statistically indistinguishable as drivers of relocation decisions. Safety is no longer secondary to tax—it is co-equal with it. New Zealand’s geographic distance, once a liability, has inverted to become a permanent structural advantage that no European, Gulf, or Asian competitor can replicate.

Italy proves the model works: growth from 226 to 1,495 participants through two price increases (€100K → €200K → €300K), each met by higher uptake. Switzerland sets the pricing benchmark. The peer-reviewed academic evidence is settled: foreign high-skill talent is thirty times more responsive to tax settings in its location decisions than domestic equivalents. These are not projections. They are proven benchmarks from OECD member countries operating programmes TRE is designed to surpass.

Five competitor programmes closed or retreated. The vacancy will not remain open indefinitely.

Our current tax settings don’t just provoke wealthy immigrants to leave after 48 months. They also dis-incentivise them from investing in our productive economy during those 48 months.

Reforming our tax settings won’t cost us anything. It will bring billions in new crown tax revenue.