Is COL (Coles Group Limited) FIF-Exempt in New Zealand?
Yes — COL qualifies for the New Zealand FIF exemption under section EX 31 ITA, based on the IRD approved Australian-share list for FY 2026-27.
✓ Last verified against IRD list
2026-04-30 (FY 2026-27). The IRD republishes the approved list annually — verify the current year's list before filing IR3.
The 4 EX 31 exemption tests for COL
| Test | COL |
|---|---|
| 1. Listed on official list of ASX Limited | ✓ Yes — quoted on ASX official list. |
| 2. Australian tax-resident (not foreign-resident under DTA) | ✓ Yes — incorporated and tax-resident in Australia. |
| 3. Maintains franking account | ✓ Yes — operating Australian dividend-paying company. |
| 4. Not stapled stock | ✓ Yes — single ordinary share, not part of a stapled security. |
What the exemption changes for COL holders
- Cost basis is excluded from the NZ$50,000 FIF de minimis. If your only foreign holdings are exempt ASX shares like COL, you never trigger FIF rules regardless of size.
- No FDR (5%) or CV calculation on the holding. You ignore the share entirely for FIF income purposes.
- Dividends are taxable in NZ as overseas dividend income. Reported on IR3 gross of any Australian withholding tax, with the AU WHT (15% on unfranked under the DTA, 0% on franked) creditable as a foreign tax credit. Australian franking credits themselves are not creditable in NZ.
- Capital gains from selling COL are generally NOT taxable in NZ unless you are a share trader or acquired the shares with intent to sell. Standard share-trader-vs-investor analysis applies.
Important caveats
The IRD list changes annually. A company on the list for FY 2026-27 may not be there next year — for example, if it relocates tax residency offshore, undergoes a corporate restructure that breaks Australian residency, or is removed by the Commissioner. Always verify the current year's list at the IRD website before filing.
Dual-listed companies need careful handling. Some ASX-listed companies (including past examples like Rio Tinto and the unified BHP) have or had non-Australian-resident parallel listings. Only the Australian-resident line qualifies for EX 31 — verify which entity issued your shares.
Stapled securities and trusts may have parts that are not exempt even if the operating company line qualifies. Check the holding's prospectus or annual report for franking-credit balance and tax-residence disclosures.
Related Calculators
Source
IRD's annual approved Australian-share list (EX 31). Always verify against the current year's list at ird.govt.nz Foreign Investment Funds — Exemptions.