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A Portfolio Investment Entity (PIE) is a special type of investment fund structure in New Zealand that receives a favourable tax treatment compared to direct investing. PIE funds include most KiwiSaver funds, managed funds, cash PIEs (such as PIE term deposits offered by banks), and listed PIEs on the New Zealand stock exchange. The key defining feature is that investors in PIEs are taxed at their Prescribed Investor Rate (PIR) rather than at their full marginal income tax rate. The PIR is an individually assigned tax rate — either 10.5%, 17.5%, or 28% — based on your taxable income in the prior two income years. This is particularly advantageous for higher-income earners, whose marginal tax rate may be 33% or 39%, because PIE fund earnings are capped at a maximum rate of 28%. For lower-income investors, the PIR can be as low as 10.5%, closely matching their marginal rate. One of the most powerful features of the PIE regime is that PIE income is not included in your taxable income for other purposes. This means PIE earnings do not count toward the Working for Families income test, the student loan repayment threshold, child support assessments, or the ACC earner levy calculation. This makes PIE funds highly attractive for families close to WFF abatement thresholds or student loan repayment obligations. KiwiSaver funds are PIEs — so all KiwiSaver earnings are subject to PIR tax, not marginal tax rates. The tax is deducted directly by the fund manager and paid to Inland Revenue on your behalf, so no tax return is required in respect of PIE income for most investors. For non-resident investors, a separate Notified Foreign Investor (NFI) regime provides reduced withholding tax rates on certain types of income, making New Zealand PIE funds competitive for offshore investors. The income that a PIE fund allocates to each investor is called Portfolio Investor Allocated Income (PIAI).
PIE Tax = Portfolio Investor Allocated Income (PIAI) × Prescribed Investor Rate (PIR); PIR = 10.5% if prior 2-year income ≤ $14,000; PIR = 17.5% if prior 2-year income ≤ $48,000; PIR = 28% otherwise
- 1Determine your Prescribed Investor Rate (PIR) by looking at your taxable income in the previous two income tax years. Use the lower of the two years. If both years' income was under $14,000, your PIR is 10.5%. If either year's income was between $14,001 and $48,000, your PIR is 17.5%. Otherwise it is 28%.
- 2Notify your PIE fund provider of your correct PIR when you invest. If you do not provide a PIR, the fund must use the default rate of 28%. Your PIR applies to all your PIE investments with that provider.
- 3The fund manager calculates the income earned by the fund and allocates a proportional share to each investor — this is your Portfolio Investor Allocated Income (PIAI). The allocation reflects your share of dividends, interest, rent, and capital gains within the fund.
- 4The fund manager deducts PIE tax at your PIR from your allocated income and pays it directly to Inland Revenue on your behalf. This happens automatically — you do not need to calculate or pay PIE tax yourself.
- 5Your PIE income and the tax paid on it are not included in your IR3 income tax return as taxable income. Inland Revenue reconciles PIE tax separately. If you used a PIR that is lower than the correct rate, you owe the underpaid tax — but if you overpaid, you generally cannot get a refund (an exception applies if the overpayment results from using a higher PIR by mistake).
- 6At year end, your PIE fund provider sends you an annual PIE income statement showing your PIAI and the PIE tax deducted. If your income has changed significantly, review your PIR and update it with your provider at the start of the new tax year.
- 7If you are a non-resident investor and eligible for the Notified Foreign Investor (NFI) regime, you register with IR and provide your NFI status to the fund. The fund then applies specific withholding tax rates that may be more favourable than standard non-resident withholding tax.
PIE income does not appear in the investor's income tax return
$8,000 × 28% = $2,240 PIE tax. At marginal rate: $8,000 × 33% = $2,640. Saving = $400. The benefit grows substantially for 39% taxpayers: $8,000 × 39% = $3,120 vs $2,240, saving $880.
PIR of 10.5% matches the lowest marginal income tax rate — no disadvantage from PIE structure
$1,500 × 10.5% = $157.50. This is exactly what the investor would pay at their marginal rate, so there is no disadvantage from investing through a PIE at this income level.
If PIE income were included, family income would be $44,000 — above the threshold, triggering abatement of $351
PIE income is excluded from the WFF income test. The family's $3,000 KiwiSaver return does not push them above $42,700, so their full WFF entitlement is preserved — saving approximately $810/year in avoided abatement.
Using a PIR lower than your correct rate requires you to pay the difference — using too high a rate does not entitle you to a refund
PIE tax paid at 10.5%: $525. Correct tax at 28%: $1,400. Shortfall: $875, which must be included as additional tax in the IR3 return. Always use the correct PIR to avoid year-end surprises.
A surgeon earning $350,000 per year invests through a KiwiSaver PIE fund and pays 28% on fund returns rather than 39% marginal rate, saving 11 cents on every dollar of investment return within the fund.
A working family earning $40,000 combined keeps their PIE/KiwiSaver fund returns outside the WFF income calculation, preventing those returns from triggering abatement of their Family Tax Credit., where accurate pie fund tax nz analysis through the Pie Fund Tax Nz supports evidence-based decision-making and quantitative rigor in professional workflows
A retiree on a small fixed income of $12,000 per year notifies their PIE cash fund of a 10.5% PIR, ensuring their term deposit interest inside the PIE is taxed at the same rate as their other income — not at the default 28%.
A fund manager running a multi-rate PIE calculates each investor's PIAI at year end, deducts PIE tax at each investor's individual PIR, and files the PIE tax return with Inland Revenue — all without the investors needing to take any action.
A non-resident investor registers as a Notified Foreign Investor and provides their NFI status to a New Zealand property PIE fund, qualifying for a reduced withholding rate on distributions compared to standard non-resident investor rates.
PIR Mismatch — Lower Rate Used
If you used a PIR that is lower than your correct rate, the shortfall in PIE tax must be included in your IR3 income tax return and paid to IR. The shortfall is treated as additional income tax, not as PIE tax, so it may also affect your provisional tax obligations for the following year.
PIE Cash Funds (PIE Term Deposits)
Several New Zealand banks offer PIE term deposits (sometimes called 'PIE savings accounts'). These work like standard term deposits but are structured as PIE funds, meaning interest is taxed at your PIR rather than at your full marginal rate. For investors on 33% or 39% marginal rates, this provides a meaningful after-tax return advantage over standard term deposits.
Foreign Investment PIEs (FIPs)
Foreign Investment PIEs are PIEs that invest predominantly in overseas assets. They use a different tax calculation method — the Fair Dividend Rate (FDR) method or cost method — to calculate income on foreign investments. The income is still allocated to investors as PIAI and taxed at their PIR.
Multi-Rate PIEs
Multi-rate PIEs (MRPs) are the most common type and calculate tax at each investor's individual PIR. They contrast with single-rate PIEs (which apply a flat rate to all investors). KiwiSaver funds and most managed funds are MRPs, allowing each investor to receive their individually appropriate tax treatment.
Exit PIE Tax on Withdrawal
When you withdraw from a PIE fund (other than KiwiSaver, which has specific conditions), the fund calculates and deducts any outstanding PIE tax on your allocated income up to the withdrawal date before releasing the funds. This ensures all PIE tax is settled before you receive the proceeds.
| Prior 2-Year Income Condition | Prescribed Investor Rate (PIR) |
|---|---|
| Both prior years' income ≤ $14,000 | 10.5% |
| Either prior year income $14,001–$48,000 | 17.5% |
| Either prior year income > $48,000 | 28% |
| Default rate (no PIR provided) | 28% |
| Maximum PIR | 28% |
| Top marginal income tax rate | 39% |
| PIE income included in WFF test | No |
| PIE income included in student loan test | No |
What is a Prescribed Investor Rate (PIR) and how do I calculate mine?
Your PIR is the tax rate that applies to your PIE fund income. It is based on your taxable income in the two income tax years before the current year. If your income in both prior years was $14,000 or less, your PIR is 10.5%. If your income in either year was between $14,001 and $48,000, your PIR is 17.5%. If your income was over $48,000 in either year, your PIR is 28%.
Do I need to include PIE income in my tax return?
Generally no. PIE income is taxed at source by the fund manager, who pays the PIE tax directly to IR. You do not include PIE income as part of your taxable income in your IR3 return. However, if you used a PIR that is lower than your correct rate, you must declare the shortfall in your return. If you used too high a PIR, you cannot generally get a refund.
Is KiwiSaver a PIE fund?
Yes. All KiwiSaver funds are structured as PIEs. This means all investment returns within your KiwiSaver account — interest, dividends, and capital gains — are taxed at your PIR rather than your marginal income tax rate. This is one of the key tax advantages of saving through KiwiSaver compared to investing directly.
Why doesn't PIE income affect my Working for Families or student loan?
By law, PIE income is specifically excluded from the income definitions used for Working for Families, student loan repayments, ACC earner levy, and child support assessments. This was a deliberate policy decision to encourage investment through PIE structures. It means that earning returns through a PIE fund does not reduce WFF credits or trigger higher student loan repayments.
What happens if I don't notify my PIE fund of my correct PIR?
If you do not provide a PIR (or provide an incorrect higher PIR), the fund defaults to 28% — the highest PIR. This means you may overpay PIE tax if your correct PIR is lower. Overpayments at the wrong PIR are generally not refundable. If you provide a lower PIR than you are entitled to, you must top up the tax through your IR3 return.
What is Portfolio Investor Allocated Income (PIAI)?
PIAI is the share of the PIE fund's total income allocated to each investor based on their proportion of the fund. The fund calculates the total income — dividends, interest, rents, and realised capital gains — and allocates each investor their share. PIE tax is then deducted from each investor's PIAI at their PIR.
Are listed PIEs on the NZX taxed the same way as KiwiSaver PIEs?
Listed PIEs (LPIEs) are PIE funds that are listed on the New Zealand Stock Exchange, such as some property and infrastructure funds. Investors in LPIEs receive PIE income and pay tax at their PIR, just like unlisted PIEs. However, the unit price may move on the exchange based on market supply and demand, separate from the underlying net asset value.
What is the Notified Foreign Investor (NFI) regime?
The NFI regime applies to non-resident investors in New Zealand PIE funds. By registering as an NFI with Inland Revenue and notifying the fund, non-resident investors may pay reduced withholding tax rates on certain income types — particularly interest and dividends — compared to the standard non-resident withholding tax rates. This makes New Zealand PIE funds more competitive for international investors.
Pro Tip
Review your Prescribed Investor Rate at the beginning of every new tax year. Your PIR is based on your income from the prior two years, so a significant income change — promotion, starting a business, going part-time, retiring — may shift you to a different rate band. Notifying your fund provider of the updated PIR early in the year ensures you are not overtaxed (or undertaxed) on PIE income throughout the year.
Did you know?
The PIE regime was introduced in 2007 specifically to encourage New Zealanders to invest through managed funds rather than directly. By capping the tax rate at 28% regardless of marginal rate, the government effectively created a tax incentive for high-income earners to invest through funds — and the simultaneous launch of KiwiSaver used this framework to make superannuation saving tax-efficient from day one.