SNOOPY,

Thanks for taking time to reply.
The question isn’t relating to my own tax obligations really more what tax is being taken out before I get a to see a dollar 💵

-Chinese tax residents are accessed on their worldwide income and there is a dual tax agreement with NZ & AUZ. The updated NZ China dual tax agreement was drafted 2 months ago and is yet to be in force.

Effectively ( NZ & China) (AUZ & China) have the same arrangement as (NZ & AUZ)
There is a host of other rabbit holes relating to China Tax liabilities which are greatly beneficial (Possibly why they are buying so many NZ assets)

1) Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State.
2) However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed
3) 15 percent of the gross amount of the dividends in all other cases

-Australia unlike New Zealand, which exempts only imputed non-cash dividends from NRWT (and has a separate FITC regime for imputed cash dividends), Australia exempts fully imputed (franked) dividends from non-resident withholding tax. This means a New Zealand investor receiving a dividend which has full imputation credits attached will not be subject to the 15% withholding tax (as provided in the double tax agreement).
In addition, certain foreign-sourced dividends paid by an Australian company to a non-resident shareholder are also exempt from Australian withholding tax.


I have a sound knowledge of the Tax requirements of buying shares as a Non Tax Resident off the ASX & NZX respectively.
Where it is going fuzzy is buying shares on the ASX of NZ dual listed company company (MEZ)

1) If I buy shares in BHP which are fully franked on the ASX as a non tax resident there is no Liability for NRWT as franking credit 30% offsets NRWT 15%
2) If I buy MEL shares on NZX carrying imputation credit (28%) this does not offset NRWT 15%, however supplementary dividend payment can (How do you know if company does this?)
3) There is no CGT tax as as Non Tax resident in AUZ, in NZ there most likely will be with my trading frequency.
4) The dividend payment for MEZ on the ASX shows dividend 100% unfranked with 15% NRWT applied.

5) So my interpretation as a non resident of AUZ & NZ is:

-MEL on NZX makes a profit of $550 million NZD pays 28% tax on the profit to IRD then distributes the dividend to me subtracting an additional 15% NRWT to pay IRD
-MEZ on ASX makes a profit of $550 million NZD pays 28% tax on the profit to IRD then subtracts (15% NRWT given to IRD then offset by supplementary dividend, cost neutral process) then converts to AUD and subtracts 15% NRWT and pays ATO
-BHP on ASX makes a profit of $550 million AUD pays 30% tax on the profit to ATO then pays me dividend

They reason for the questions is probably obvious but I am trying to see which method has the least tax overall the reason for complicating it with NZ dual listed companies is I really like the NZ power companies.
I would have thought there might be a way of MEZ getting the same overall tax treatment as BHP?

Thanks for your time.