Estonian Company Run from New Zealand: Tax Rules

Many New Zealand entrepreneurs form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from New Zealand. New Zealand income tax looks at the company and at its owner. The company side: a company is a New Zealand resident if its head office or its centre of management is in New Zealand, or if its directors exercise control of it there. The owner side: an Estonian company controlled by New Zealand residents is a controlled foreign company, and a resident with an income interest of 10% or more can be taxed on its passive income. And there is no tax treaty between Estonia and New Zealand. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a New Zealand tax adviser before you form or buy the company. We read the Income Tax Act 2007 (version as at 4 September 2026) on the official site of New Zealand legislation, legislation.govt.nz, and the list of Estonia's tax treaties published by the Estonian Ministry of Finance, on 22 October 2026.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In New Zealand: the company side

Four bases for residence. A company is a New Zealand resident if it is incorporated in New Zealand, if its head office is in New Zealand, if its centre of management is in New Zealand, or if its directors, in their capacity as directors, exercise control of the company in New Zealand, even if their decision-making also occurs outside New Zealand (Income Tax Act 2007, section YD 2(1)).
Visitors. Since 1 April 2026, for a foreign company the activities in New Zealand of a non-resident visitor are disregarded for the head-office, centre-of-management and director-control bases (section YD 2(1C)). A non-resident visitor is, among other conditions, a natural person whose visit and total presence in an 18-month period are 275 days or fewer, who was not resident in New Zealand before, and who does not work for a New Zealand resident or offer goods or services in New Zealand (section YD 1B(2)).

An Estonian OÜ is incorporated in Estonia, so the first basis does not apply. If you live in New Zealand and manage the company from there, its centre of management or the control by its directors can be in New Zealand — and then New Zealand treats it as a New Zealand resident. Your New Zealand tax adviser answers that with the facts of your case.

In New Zealand: the owner side

Controlled foreign company. A foreign company is a controlled foreign company (CFC) if a group of 5 or fewer New Zealand residents has control interests of more than 50% in any one category, if a single New Zealand resident holds a control interest of 40% or more (unless a non-associated non-resident holds at least as much), or if 5 or fewer New Zealand residents control the company's affairs through the shareholder decision-making rights (section EX 1(1)).
10% threshold. A person has attributed CFC income or loss only with an income interest in the CFC of 10% or more for the accounting period (section EX 14(1)); the interests of associated persons are added (section EX 15).
Active companies. A CFC is a non-attributing active CFC when its attributable CFC amount divided by its gross income is less than 0.05 (sections EX 21B and EX 21D(2), (4)). The attributable amount includes dividends, royalties, rents, income from services physically performed in New Zealand and, in defined cases, income from personal services performed by a New Zealand resident associated with the company (section EX 20B(3), (9)).

No tax treaty between Estonia and New Zealand

New Zealand is not on the list of Estonia's tax treaties published by the Estonian Ministry of Finance. So no treaty decides which country a company resident in both is resident of, and no treaty limits the tax either country charges on dividends or management fees. Each country applies its own law; whether and how double taxation is relieved then depends on each country's domestic rules — a question for your New Zealand tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the company is managed, and by whom. These are the facts the New Zealand residence rules look at.
Who owns it. The shares of New Zealand residents decide whether it is a controlled foreign company, and your own share whether income is attributed to you.
What the company earns. Passive income and services performed in New Zealand count towards the attributable amount.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. New Zealand tax returns and New Zealand tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; New Zealand tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in New Zealand if I run it from New Zealand?

It can be. New Zealand treats a company as resident if its head office or its centre of management is in New Zealand, or if its directors exercise control of it there (Income Tax Act 2007, section YD 2(1)). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). If New Zealand residents control the company, it is a controlled foreign company, and an owner with an income interest of 10% or more can be taxed on its attributable income, unless that amount is less than 5% of its gross income (sections EX 1, EX 14, EX 21B and EX 21D). There is no tax treaty between Estonia and New Zealand. Ask a New Zealand tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from New Zealand: what is taxed where