New Zealand’s Active Investor Plus (AIP) golden visa scheme has done exactly what the government hoped. In its first 13 months it attracted $1.72 billion in investment, a dramatic turnaround from the previous version that managed just 116 applications over two-and-a-half years. By 20 May 2026, 730 applications covering 2,390 people had come in, representing a potential minimum $4.3 billion.
The front door works. The problem, according to a review published today by law firm MinterEllisonRuddWatts, is what happens once these investors are inside. The biggest obstacle is not the visa. It is the tax code.
The relationship stays ‘temporary and transactional’
The review found tax settings are “one of the strongest tensions” underlying AIP, regularly discouraging visa holders from putting down roots and keeping their relationship with New Zealand exactly that, temporary and transactional. MinterEllisonRuddWatts tax partner and report co-author Andrew Ryan said the rules can stop visa holders making a “deeper commitment” to New Zealand, including moving here permanently.
The mechanism is the Foreign Investment Fund (FIF) regime, which captures residents’ offshore holdings including equities, venture capital and private companies. The common fear is double taxation on worldwide income and assets once a visa holder becomes a New Zealand tax resident, with bilateral treaties patching only part of the problem.
Americans, who make up nearly 40% of applicants, are the most exposed. US citizens are taxed on worldwide income regardless of where they live, opening the door to double or even triple taxation without careful structuring. The rational response is to stay at arm’s length, and that is what they are doing. The vast majority of AIP holders are passive investors, parking money in listed stocks, bonds, managed funds and private credit rather than backing local companies.
That directly undercuts the pitch. The whole point of the scheme is that wealthy investors bring business acumen, networks and follow-on capital. If the tax code makes it uneconomic to engage, the country gets the money but not the value.
The property pathway is barely moving either
Tax is not the only friction. The property route, the most obvious way to convert residency interest into genuine roots, is crawling. As of 7 May 2026, the Overseas Investment Office had approved just 16 property purchase applications since the foreign buyer rules changed on 6 March 2026, against those 730 visa applications. That is 11 in Auckland, 4 in Queenstown-Lakes and 1 in Hawke’s Bay.
Lawyer Nicola Hoobin noted that even minor surveying details, such as whether a title boundary stops short of the mean high water springs, can decide whether a property qualifies, and that it could take up to a year before the law became less complex. A Bayleys report found the changes had “created real activity” but “not the tidal wave” some had predicted.
The warning is not new. Writing in Forbes in September 2025, Stuart Nash of Nash Kelly Global put it plainly: “Wealthy families don’t just want a visa, they want a safe haven where they can build a life. Without the ability to purchase a home, we risk losing exactly the kind of long-term investors New Zealand should be attracting.”
Why they still come
Demand is genuine, and it says something about the world right now. The review found New Zealand attractive because it is stable and safe, with high trust in institutions and good quality of life. One investor summed it up as “cleaner air and no missiles.” That safe-haven appeal explains why applications from China more than doubled between August 2025 and February 2026, from 45 to 95.
In September 2025, Prime Minister Christopher Luxon framed the competition bluntly: “If you are a major international investor, New Zealand is just one of 195 countries all competing for your money and your ideas. The competition is fierce, and the solution is actually competing harder.”
The 2028 forcing function
Here is the pressure point. Growth category investors who entered from April 2025 finish their three-year minimum investment period from 2028. If the tax settings are still hostile or uncertain, that cohort has a rational reason to repatriate rather than reinvest. A wave of exits would hit liquidity in the private credit and managed fund markets that have absorbed much of the $1.72 billion, and it would dent the scheme’s reputation right as momentum builds.
For fund managers, private capital advisers, developers and professional services firms building practices around AIP investors, the review is a material signal. The deal flow is real, but the after-tax pathway for investors who want to go deeper remains murky. The government built a compelling front door. Unless it fixes the FIF and double-taxation issues before 2028, it risks turning a genuine policy win into a capital flight story.