If the FSP is registered as a limited partnership or look-through company and the partners or shareholders are not domiciled in New Zealand then the profits of the FSP can be attributed to its shareholders and this tax is paid at the place of registration of the partner or shareholder. This is because the Limited Partnership and Look Through Company structures attribute the losses and income to their shareholders not to the company. As long as the shareholders are not tax residents of New Zealand, they will pay tax in their country of residency. As long as the Company does not make money from New Zealand sources, it follows that the FSP is not taxed in New Zealand in the same manner as the trust regime for New Zealand non-resident trusts.
The potential for tax structuring created by this regime is immense. The FSP can borrow money from its own shareholders and then invest this money into property; shares etc and then repay the loan at interest to a non resident trust whose beneficiaries are the shareholders, thus providing both tax minimization and asset protection simultaneously.
Generally these structures cost between $10,000 USD and $20,000 USD just to build the trust structures. We will be able to offer the services all as a package, lowering the total cost. Contact email@example.com