Capital gains tax proposal: How it compares to the rest of the world

The recommended capital gains tax (CGT) rate would be among the world's highest, according to Simon Bridges - but is that true?

"The [Tax Working Group] has recommended one of the highest rates of capital gains tax in the world," the National leader said on Thursday. 

The Government's Tax Working Group has recommended a CGT to be set at the income-earner's top tax rate, likely to be 33 percent for most people. 

So how does that compare to other countries?

A CGT rate of 33 percent is relative to some New Zealand allies. 

In the UK, it varies according to the type of asset and level of income – companies and shares are taxed at a top rate of 20 percent, for example, while a 28 percent rate mostly only applies to property. 

But 33 percent is significantly higher than the likes of Iceland which charges a CGT at just 22 percent, alongside Spain, which charges a CGT of up to 23 percent.  

The country with the highest CGT rate is Denmark, where the maximum tax rate is set at 42 percent - well above the proposed 33 percent for New Zealand. 

Countries and territories without a CGT include Singapore and Hong Kong. 

In the United States, how much you pay in CGT depends on how long you held the asset before selling it. CGT rates on most assets held for less than a year correspond to ordinary income tax brackets from 10 percent up to 37 percent. 

In Australia, most personal assets are exempt from CGT - including your home, car and personal assets, which is similar to what's been recommended in the Tax Working Group's report. 

Companies in Australia must pay 30 percent tax on any net capital gains. Individuals, however, pay the same rate as their income tax rate, the same as has been proposed for New Zealand. Australia's tax brackets can be seen here.  

Australia only charges at your personal income tax rate if you hold the asset for less than a year. If you (or a small business) hold the asset longer than a year, you receive a 50 percent discount. 

The Working Group's proposal doesn't split rates according to the time-period of asset ownership.

History of CGT in New Zealand

Introducing a CGT in New Zealand was campaigned on by former Labour Party leader Phil Goff in 2011, and was carried on by David Cunliffe in 2014. 

In 2015, former National Prime Minister John Key introduced the Bright-Line Test, requiring income tax to be paid on any gains from residential properties that were sold within two years of purchase. 

That two-year limit was increased by the current Government last year to five years.

When Jacinda Ardern became Labour leader in 2017, she scrapped the party's capital gains policy a week before the election, in the face of immense criticism and attack ads from the National Party. 

But in November 2017, Finance Minister Grant Robertson set up the Tax Working Group, sparking speculation the Government was interested in a CGT. 

The Tax Working Group released its interim report in September last year, which provided some details on how it thought tax could be fairer in New Zealand. 

The Prime Minister said on Thursday the Government will give its response to the recommendations of the Working Group's most recent report once the public has had the opportunity to respond. 

The official response will be given in April.