I bought a commercial investment property in New Zealand about 15 years ago under a New Zealand company and I as director. The property will start making significant profits now and I asked my NZ accountant if their is a way to minimise the company tax which is currenlty 28% on profits in NZ. He advised to set up a NZ Look Through Company (LTC) and have an Australian Trust as the owner of LTC. Everything was running smoothly until the Intrernal Revenue (NZ Tax Office) requested the ATO to confirm the following: 1. The company is not considered a tax resident of Australia 2. Would remain a non tax resident of Australia should the company become a LTC 3. Is not liable for tax, as an Australian resident on any income. Before I contact ATO can anyone share any light on this issue and best structure to minimise tax on a NZ Commercial Property owned by NZ Company? My NZ accountant also suggested altenrative is you sell the company to a NZ trust but would their be any capital gains tax on the sale in Australia. Any feedback would be greatly appreciated.