What this choice actually costs you
The 28% ceiling: an 11-point head start that repeats every year
Tom is a Wellington engineer on $130,000: a 33% bracket, 39% in his bonus years. Every dollar of dividend income from directly held ETFs is taxed at his marginal rate. The identical portfolio inside a PIE fund is taxed at his PIR, which the law caps at 28% no matter what he earns.
Since 1 April 2025 the PIR bands sit at: 10.5% for taxable income up to $15,600, 17.5% up to $53,500, and 28% beyond: assessed on the lower of your last two years' income. For anyone in the 30%+ brackets, the PIE wrapper is a permanent, legislated discount of 2 to 11 points on investment tax.
One piece of housekeeping keeps it that way: certify the correct PIR with your provider each year. Too low, and IRD bills the shortfall at your marginal rate with the discount forfeited; unnecessarily high, and recovering the overpayment means chasing a refund through your return.
Fifteen years compounding at two different tax rates
Small annual differences become large terminal ones. Take $100,000 producing a 5% taxable return each year. Taxed at the 28% PIR, it compounds at 3.6% net and reaches about $170,000 in fifteen years. Taxed at 39%, it compounds at 3.05% and reaches about $157,000.
That $13,000 gap assumes identical gross returns. Hand the direct ETF its fee advantage: say 0.40% a year, and it claws back roughly half the difference, which is why the comparison genuinely flips for investors whose PIR isn't capped: at a 17.5% PIR versus a 17.5% marginal rate, the tax edge is zero and the direct fund's lower fee wins outright.
The rule that falls out of the arithmetic: your bracket picks your wrapper. Above $53,500 of income, tax dominates fees — PIE. Below it, fees dominate tax: direct. Run your own rates in the simulator above; the crossover is sharp.
The $50,000 tripwire: FIF tax on money you never received
Here is the rule that ambushes DIY investors. Once your directly held foreign shares — US ETFs, most non-exempt foreign stock — exceed $50,000 NZD of original cost, the Foreign Investment Fund regime applies to the entire holding. Under the common Fair Dividend Rate method, IRD deems you to have earned 5% of the portfolio's opening market value and taxes that at your marginal rate, whether the market rose, fell, or paid you nothing.
Concretely: $100,000 of US index ETFs, deemed income $5,000, tax at 39% = $1,950 for the year: even if the fund paid $1,300 of actual dividends and the market finished down. Inside a PIE, the fund runs equivalent calculations internally at your capped 28% and you never file a thing; the same exposure costs roughly $1,400 with zero paperwork.
Practical play for direct investors near the line: the threshold is cost basis, not market value, and it applies per person: a couple holds $100,000 of foreign cost jointly before FIF bites. Cross it knowingly or don't cross it at all; discovering FIF three years late, with returns to amend, is the expensive version of this lesson.