IR1261 and the FIF disclosure: what to report about your foreign investments

People often mix up two pieces of paperwork. The Overseas income summary (IR1261) breaks down the overseas income in box 17B of your IR3 by type and jurisdiction (IR3G p19). The FIF disclosure lists the foreign investments themselves, with their names, countries and values (IRD disclosure page, 5 October 2026). The IR1261 is required from the 2023 tax year on even where a disclosure exemption applies (IR461 p21). This guide covers what each one asks for, who is exempt from the disclosure, and how to fill them in.

Two different things

So an individual over the $50,000 threshold with ordinary US and UK shares on FDR will usually complete an IR1261 but may well be exempt from the FIF disclosure. Check both every year.

What goes on the IR1261

The IR1261 has one section per type of income and jurisdiction (IR3G p19). For FIF investors the two common types are FIF income and foreign dividends. For each line you give the income in NZ$ and the overseas tax.

For FIF income, Inland Revenue allows two approaches (IRD “Reporting your overseas income”, 29 May 2026):

• break FIF income down by jurisdiction; or
• put all FIF income under the jurisdiction “overseas” (or “XX” if your software does not offer “overseas”).

If you combine several FIFs into one line, keep a supporting report showing how you got there. An investment adviser’s report is acceptable (same page). The totals across the IR1261 should agree with boxes 17B and 17A of the IR3.

Worked example: FDR year

An individual held a US shares ETF worth NZ$60,000 and a UK company worth NZ$20,000 on 1 April 2025, with a total cost of $70,000, so the FIF rules apply. FIF income under FDR is $4,000, with $180 of creditable US tax on the ETF’s dividends (the full workings are in the IR3 guide).

The alternative is a single line: FIF income, “overseas”, $4,000, tax $180, backed by a report. The UK line shows no tax because UK dividend tax is not creditable (IR461 p20), and in this example none was withheld anyway.

The dividends themselves ($1,200 from the ETF, $600 from the UK company) do not get their own dividend lines, because under FDR they are not taxed separately (IR3G p21).

Other common cases

A bad year on CV. If the same portfolio had fallen to $54,000 and $19,000, CV would be a loss of $5,200, reduced to nil. FIF income would be $0, so there would be no FIF income lines to show and no credit for the foreign tax. Our calculator’s stated rule is one line per type and country, except that when comparative value is reduced to nil any remaining FIF income goes on one “overseas” line, so the lines always add up to the return.

Under the $50,000 threshold. You report the dividends instead. For example, $1,200 of gross US dividends with $180 withheld under a W-8BEN goes on a dividends line for the United States: income $1,200, tax $180. See dividends under $50,000 and our dividends tool.

Exempt ASX shares alongside FIF holdings. Dividends from qualifying ASX-listed companies are taxed as ordinary dividends (IR461 p7), so they go on a dividends line for Australia, separate from your FIF income lines. Australian franking credits are not creditable (IR461 p20). See the ASX guide.

Are you exempt from the FIF disclosure?

Inland Revenue issues an International Tax Disclosure Exemption each year, usually in the April Tax Information Bulletin. IR461 p21 summarises who it covers. Most people are exempt if their interests are:

• under 10% and non-attributing; or
• within the $50,000 threshold; or
• direct interests under 10%, using FDR or CV, in a country New Zealand has a double tax agreement with, other than a PIE, a widely held company, a superannuation fund or a guaranteed investment fund.

The exemption does not remove the duty to return FIF income (IR461 p21), and it does not remove the IR1261. The IR3 guide says investments in treaty countries using CV or FDR may not need an extra disclosure (IR3G p53).

We have not read the 2026 exemption notice itself, and the wording of the categories matters (for example, what counts as a widely held company), so if you are close to a boundary, read the notice or ask your accountant. Inland Revenue’s exemptions page still refers to the 2019 notice (ITR30); IR461 is the more current summary.

How to file a FIF disclosure

If you do need to disclose, Inland Revenue’s disclosure page (5 October 2026) sets out the steps:

1. In myIR, choose File or amend a return.
2. In the disclosures section, select “This return will include CFC/FIF disclosure”.
3. Enter each investment, or upload IRD’s template.

For each investment you need its name, its country of incorporation or tax residence, and its NZ$ market value at the start or end of the income year (IRD FIF hub, 31 March 2026; IRD disclosure page).

Paper schedules also exist, by method: IR447 for FDR, IR448 for CV, IR449 for the cost method and IR443 for the deemed rate of return, plus older forms (IRD disclosure page).

Question 40 on the IR3

Question 40 asks whether you held rights in a foreign company, unit trust, superannuation scheme or life policy for which disclosure is required (IR3 2026). On our reading, if the exemption covers all your interests, no disclosure is required and the answer is no; if any interest falls outside it, the answer is yes and you file the disclosure. Our calculator does not decide this for you: when the FIF rules apply it shows a reminder to check.

Holdings on several platforms

The IR1261 is about your income, not about each platform. If you hold US ETFs on two platforms, the FIF income from both goes on the same United States FIF line (or into the single “overseas” line). In practice:

1. Get each platform’s FIF figures for the year. Sharesies and Hatch each describe an annual FIF report (single platform sources, not confirmed by IRD); for other platforms you may need to work from transaction exports.
2. Convert everything with one exchange rate method (IR461 p13).
3. Work out FDR and CV across the combined portfolio and pick one method for all of it (IR461 p14).
4. Split the result by country if you want country lines, or use one “overseas” line with a supporting report.

Our FIF calculator takes holdings from any number of platforms and gives the IR1261 lines in one place. The platform guides cover Sharesies, Hatch, Stake and Interactive Brokers.

Records to keep

• Each investment’s name, country and the 1 April and 31 March values in NZ$, with the exchange rates used (rates guide).
• The report that supports any combined “overseas” FIF line.
• Dividend statements showing gross dividends and foreign tax withheld; IRD asks for proof of overseas tax paid (IR3G p22).
• A note of why you were, or were not, exempt from disclosure that year.

The record keeping guide has the full list.

Rules checked 12 November 2026. General information, not tax advice; check with your accountant.

Questions

Is the IR1261 the same as the FIF disclosure?

No. The IR1261 summarises overseas income and tax by type and country. The FIF disclosure lists the investments and their values.

Can I put all my FIF income on one IR1261 line?

Yes. IRD allows all FIF income under the jurisdiction “overseas” (or “XX”), as long as you keep a supporting report (IRD, Reporting your overseas income).

I am under the disclosure exemption. Do I still need an IR1261?

Yes. From the 2023 tax year on, the summary is required even where a disclosure exemption applies (IR461 p21).

What value goes in the FIF disclosure?

The NZ$ market value at the start or end of the income year, with the investment’s name and country (IRD disclosure page).