Dividend imputation and international equity investment: Unilateral extension of imputation to non-resident investors

Despite the widespread adoption of company-shareholder tax integration regimes to mitigate the double taxation of distributed regimes, very few countries have extended such relief to non-resident shareholders. The constraints upon a country unilaterally extending the benefits of dividend imputation to non-resident investors are discussed. The discussion also examines the new tax regime recently introduced in New Zealand, which extends dividend imputation to certain non-resident investors in a way so that the benefits are preserved offshore irrespective of how non-resident investors are taxed there.