Foreign PIE equivalent
A foreign portfolio investment entity (PIE) equivalent is an overseas resident entity that would be eligible to be a PIE if it was a New Zealand tax resident.
New Zealand PIEs can have a foreign PIE equivalent investment that does not then breach the entity shareholding investment requirement.
A foreign PIE equivalent may also hold up to 100% of a New Zealand PIE without breaching the maximum investor interest requirement.
A land PIE will have more than half its value in land or land owning companies for any of its investment classes.
These types of PIEs have certain requirements:
- losses from the land class can only be offset against income from that same land class
- unused class land loss is ‘ring-fenced’ and can only be carried forward to reduce taxable income of the same class in later attribution periods
- the investment must be in land, a resident land investment company or a holding of more than 20% in a non-resident land investment company.
Land PIEs can choose any of the four filing options.
Land investment companies
A PIE can own shares in land investment companies, but land investment companies themselves are not PIEs.
Land investment companies:
- have at least 90% of their market value in assets made of interest in land or shares in land investment
- have a market value of $100,000 or more for at least 80% of the tax year
- meet the income source requirement.
These companies cannot have shares in a land investment company that already has shares in another land investment company.
Some investment companies hold several PIEs. The retail PIEs offer various combinations of investment for general customers to invest in. The retail PIEs then invest in the company’s wholesale PIE, which makes the actual investment.
Most multi-rate PIEs will register as retail PIEs.
PIE investor proxies
PIE investor proxies (PIPs) are intermediaries through which investors can invest into a PIE.