Bell Gully report highlights key tax considerations for digital businesses in NZ

17 September 2025

The ongoing evolution of the New Zealand tax landscape continues to raise fresh issues for digital businesses and digital asset holders.

Law firm Bell Gully has released a report discussing the key developments in New Zealand’s digital tax landscape. 

“Updated guidance on the tax treatment of cross-border software payments is under development and tax issues for remote working arrangements, digital nomads and data centre infrastructure are in focus.  New Zealand continues to mull the role of the OECD Pillars, while taxpayers are adapting to the new platform economy GST rules and enforcement activity for crypto asset transactions is ramping up,” said tax partner Graham Murray.

“While New Zealand regards itself as open for business, digital businesses face particular tax considerations and should be aware of the evolving tax environment in New Zealand.”

He said that New Zealand’s recently introduced digital nomad visa programme has drawn attention internationally, and supporting tax changes are proposed to reduce tax residence risks and tax compliance costs for those taking advantage of this new visa.  

He sees an update of the New Zealand Inland Revenue Department’s guidance on tax treatment of cross-border software payments as particularly important. Debate as to the correct classification of software payments continues globally, and the update is an opportunity to provide clarity for businesses. 

Crypto asset transactions are producing novel tax issues, ranging from capital/revenue boundary questions to the issues around the correct sourcing of income from crypto assets.   

The Big Picture: Digital Tax provides a comprehensive overview of developments within this space, looks at emerging compliance and enforcement trends, and highlights future developments that may impact digital businesses engaging with New Zealand’s tax system.


Disclaimer: This publication is necessarily brief and general in nature. You should seek professional advice before taking any action in relation to the matters dealt with in this publication.