Trading Trusts in New Zealand

A trading trust is a trust structure that actively conducts business operations. Unlike a family trust that holds passive assets, a trading trust runs a business, generates income, and manages trading activities.

What Is a Trading Trust?

A trading trust:

  • Operates a business
  • Generates income from trading activities
  • Holds business assets
  • Employs staff
  • Enters contracts in the trust’s name

The trustees manage the business on behalf of beneficiaries.

Why Use a Trading Trust?

Asset Protection

Separate business assets from personal wealth. If the business faces claims or creditors, your personal assets are protected.

Succession Planning

Makes transferring business ownership to the next generation easier and more tax-efficient.

Income Distribution

Flexibility to distribute profits to beneficiaries in tax-effective ways.

Limited Liability (with company trustee)

When a company acts as trustee, personal liability is further reduced.

How It Works

  1. Trust established with trustees and beneficiaries
  2. Business operates under the trust structure
  3. Income generated from trading activities
  4. Profits distributed to beneficiaries according to trustee discretion
  5. Assets held by the trust, not individuals

Trading Trust vs Company

FeatureTrading TrustCompany
LiabilityTrustees personally liable (unless company trustee)Limited liability
FlexibilityHigh – discretionary distributionsLower – shareholder dividends
Tax rate33% (trustee income)28% (company tax)
ComplianceModerateHigher (Companies Office)
Asset protectionGood (with company trustee)Good

Common Business Structures Using Trading Trusts

Retail Businesses

Shops, cafes, restaurants operating through a trust.

Professional Services

Consultants, contractors, trades operating as a trust.

Property Development

Development projects held in trading trusts.

Family Businesses

Multi-generational businesses with family beneficiaries.

Tax Considerations

Trustee Income Tax

Income retained by trustees is taxed at 33%.

Beneficiary Income

Income distributed to beneficiaries is taxed at their personal rate.

No Company Tax Benefits

Trading trusts don’t get the 28% company tax rate.

Loss Utilization

Losses can be offset against beneficiary income (with careful planning).

Asset Protection Strategy

Best Practice Structure

Company as Trustee → Trading Trust → Business Assets

This provides:

  • Limited liability through the company
  • Asset protection through the trust
  • Flexibility in income distribution

What’s Protected

  • Business equipment and stock
  • Intellectual property
  • Business premises
  • Cash reserves

What’s Not Protected

  • Personal guarantees given by trustees
  • Debts incurred before transferring to trust
  • Fraudulent transfers

Setting Up a Trading Trust

1. Establish the Trust

Draft a trust deed suitable for trading activities.

2. Appoint Corporate Trustee

Use a company as trustee to limit personal liability.

3. Transfer Business Assets

Move business assets into the trust (consider tax implications).

4. Register for GST

If turnover exceeds $60,000.

5. Set Up Bank Accounts

In the trust’s name.

6. Obtain IRD Number

For the trust.

7. Insurance

Ensure adequate business insurance.

Ongoing Obligations

  • Annual financial statements
  • Trustee resolutions documenting decisions
  • Distribution minutes for income allocations
  • IRD returns for trust and beneficiaries
  • Trust administration and record-keeping
  • Compliance with Trusts Act 2019

Costs

  • Setup: $3,500 – $6,000+ (including company trustee)
  • Annual compliance: $1,500 – $3,000+
  • Accounting and tax: $2,000 – $5,000+ per year
  • Legal reviews: $500 – $2,000 as needed

When a Trading Trust Makes Sense

  • You run a business with significant risk exposure
  • You want asset protection for your business
  • You’re planning succession to family members
  • You need flexibility in profit distribution
  • You have a profitable business and want tax planning options

When NOT to Use a Trading Trust

  • You’re seeking limited liability only (use a company instead)
  • Your business has high risk and you can’t get company trustee (personal liability remains)
  • You want the lowest tax rate (companies are 28%)
  • You prefer simpler compliance

Common Mistakes to Avoid

  1. Not using a company trustee – Leaves trustees personally exposed
  2. Poor documentation – Failing to keep proper minutes and records
  3. Mixing personal and business – Using trust assets for personal benefit
  4. Ignoring Trusts Act obligations – Not following mandatory trustee duties
  5. No succession plan – Failing to document business transition

FAQs — Trading Trusts

Can I be both trustee and beneficiary?

Yes, but you must act in the best interests of all beneficiaries, not just yourself.

Do I need a company as trustee?

Not legally required, but highly recommended for liability protection.

How do I pay myself from a trading trust?

Through salary (as employee) or distributions (as beneficiary).

Can I sell my business in a trading trust?

Yes, the trust sells the business assets and distributes proceeds to beneficiaries.

What happens if the business fails?

Trustees may be personally liable for debts unless a company is the trustee.

Can I convert my existing business to a trading trust?

Yes, but consider tax implications and timing carefully.

Is a trading trust better than a company?

Depends on your situation. Trading trusts offer distribution flexibility; companies offer lower tax and limited liability.

Do trading trusts need audits?

Only if required by trust deed or if turnover is very high (not common).