It is interesting to note that the definition of the DBA does not provide for payments for the right to use industrial, commercial or scientific equipment. This is because these amounts are taxed either under the Corporate Profits Section or in shipping and air transport items. The exclusion of these payments from the licence clause reflects the practice of the international tax treaty and recognizes that gross taxation of countries of origin may be excessive given the low profit margins. New Zealand has a welfare system that must be paid by income in New Zealand. In the absence of a totalization agreement between the United States and New Zealand, this could be one aspect of U.S. foreign taxes, where the Americans face double taxation in New Zealand. The U.S. Social Security Administration provides U.S. emigrants with a social security declaration in New Zealand so that taxpayers know exactly what they are making their contributions. All DBAs include the POP as a low-cost dispute resolution mechanism. As a general rule, the POP only provides for the relevant authorities to work to resolve the problem.

However, some POPs provisions are supplemented by arbitration provisions to eliminate cases where the relevant authorities are unable to reach an agreement. The DBA also applies to taxpayers from third countries, as the non-discrimination section applies to nationals of Australia or New Zealand. In addition, the mutual agreement procedure, information exchange articles and tax debt collection assistance articles apply when third countries are residents of tax territory that are nationals of Australia or New Zealand. The taxation of global income in New Zealand depends on your residency status. However, the treaty allows U.S. emigrants to avoid double taxation of their income in New Zealand by allowing them to benefit from U.S. tax credits if they file their return on the same value as New Zealand income taxes they already paid when filing their U.S. tax returns.

There is no totalization agreement, so it could be an area in which Americans living in New Zealand could be subject to double taxation. American emigrants can obtain more information about the New Zealand system of the U.S. Social Security Administration. There is currently no social security agreement (or totalization agreement) between the U.S. government and the New Zealand government. The U.S.-New Zealand tax treaty was signed in 1982 and a protocol was added in 2008. The treaty aims to prevent double taxation for Americans living in New Zealand and New Zealanders living in the United States from preventing U.S. citizens living in New Zealand from having to submit U.S. taxes.