The new category adds an extra level of complexity to migrant investor applications

We summarise a few key insights in relation to the AIPV category below:

Priority processing over current Investor 1 and 2 Category applications

• As of August 2022, INZ had 841 Investor applications (which includes Investor 1 and 2 Category residence applications) on hand. Some of these applications are waiting to be allocated to a Business Specialist to be assessed. The AIPV category will use a priority processing stream which will allow AIPV category applications to be allocated and processed by Business Specialists, ahead of already submitted Investor 1 and 2 Category applications

Introduction of New Zealand Trade and Enterprise (NZTE) to assist with providing direction on which investments are acceptable

• Our understanding is that NZTE will be accepting applications for funds and investments to be approved acceptable managed fund (2x) and direct investment (3x) weighting status in November 2022. The released criteria that managed funds and direct investments will be assessed against, can be found here. Further guidance will be provided in the future

A different staggered approach to meeting investment requirements

• Nomination and transfer NZD15m or weighted equivalent. Followed by a minimum tranche of investment to be approved a resident visa. The initial investment must be completed within six months (unless an extension is approved)
• Investment of a minimum of NZD7.5m or weighted equivalent into acceptable investments in the first 18 months of the 48-month investment period
• Investment of a total of NZD15m or weighted equivalent in the first 36 months of the 48-month investment period, and
• Retention of the total NZD15m or weighted equivalent in acceptable investments for the final 12 months of the 48-month of the investment period

Introduction of ‘holding investments’

• Allowing uncalled funds to be invested into bonds issued by the New Zealand government or local authorities, term deposits with New Zealand registered banks or deposits in a New Zealand bank account

A requirement to demonstrate the ability to meet a minimum standard of English

• This can be demonstrated via an acceptable English language test result (e.g. IELTS 5.0 or higher), evidence of an English speaking background or other circumstantial evidence

A time in country requirement

• A requirement for principal applicants to spend 117 days in New Zealand over a 48 month/4 year investment period

Our thoughts

Adjusting to the new AIPV category will take time. It will also take time for NZTE to process and provide further acceptable managed funds and direct investment information. It is possible that after aspects of the AIPV category are worked through, that the AIPV category may turn out to be more positive for the New Zealand economy when compared to the predecessor policy.

There are advantages to the AIPV category. New Zealand businesses and funds exploring options to obtain direct capital investment may be able to benefit from access to more capital after being approved acceptable managed fund (2x) and direct investment (3x) weighting status by NZTE. The predecessor Investor 1 and 2 Categories had attracted over NZD 12billion in investment in New Zealand (over a decade), however the investments were generally into listed equities. The AIPV category encourages more direct investments which could, in turn, create more benefits for the New Zealand economy.

From a migrant investor perspective. The new AIPV category provides a faster pathway to gaining a New Zealand resident visa, and to jump the current backlog of Investor applications. There are also other benefits including a staggered approach to investing over a four-year investment period (instead of a requirement to invest e.g. NZD10 million into equities at the outset to obtain a resident visa).

New Zealand remains the only country in the world with an indefinite Permanent Resident Visa that does not require conversion of citizenship status. This is may continue to attract foreign investment into New Zealand via the AIPV category.

The information set out above is current as of 7 October 2022.