Reviewed by John Hu, founder of John Hu Migration Consulting and Registered Migration Agent (MARN 0746141).
Australia-New Zealand dual citizenship is becoming a long-term planning direction that more and more Hong Kong investors researching New Zealand’s Active Investor Plus Visa (AIP) are paying close attention to. Rather than focusing only on surface-level questions — the investment amount, residency requirements, or processing time — a growing number of investors are thinking further ahead: after obtaining a Permanent Resident Visa in New Zealand, what’s the ultimate destination?
The roadmap to this dual citizenship strategy may sound complex, but it rests on a clear legal basis and is already being put into practice today.
Why the Dual Citizenship Strategy Is Viable
1. The Special Legal Relationship Between Australia and New Zealand
Australia and New Zealand share a legal relationship unlike any other in the world, known as the Trans-Tasman Travel Arrangement.
Under this arrangement, a New Zealand citizen entering Australia is automatically granted a Special Category Visa (SCV, subclass 444). This isn’t an ordinary visa — it’s a special legal status that allows a New Zealand citizen to live, work, and study in Australia indefinitely without needing to apply for any other visa.
A critical turning point: since 1 July 2023, under amendments to Australia’s Citizenship Act, time spent living in Australia under SCV status now counts toward eligibility for Australian citizenship — including the 12-month permanent residency requirement immediately preceding the application.
In other words: a New Zealand citizen living in Australia under an SCV is treated as an Australian permanent resident for citizenship purposes, and can file a citizenship application once general residency requirements are met — with no need to apply for any other Australian visa or permanent residency pathway.
2. Why This Is a Strategic Route Given the Current Landscape
Australia’s Subclass 188 investor visa (the mainstream investment migration visa) was formally closed at the end of 2024, replaced by the National Innovation Visa (Subclass 858) — with substantial changes to both eligibility thresholds and the review approach. Meanwhile, a large backlog remains under the old system: reportedly 14,942 people are still waiting, with a quota of only about 1,000 places per year, putting current estimated wait times at over 10 years.
Against this backdrop: AIP New Zealand → New Zealand citizenship → entering Australia via SCV → Australian citizenship via SCV is currently the only route still open to obtaining Australian citizenship through investment — and it’s fully legal, resting on a clear legal foundation established by both governments.
The Legal Mechanism, Step by Step
Step 1 — Active Investor Plus Visa: The Starting Point
AIP is the gateway into New Zealand’s permanent residency system through investment. After meeting investment conditions and receiving a Resident Visa (a conditional residency visa), the investor and their family gain the right to live, work, and study in New Zealand.
What sets AIP apart from other programs: the Approval in Principle mechanism — INZ reviews and approves the application before the investor transfers any funds. This is a risk-protection mechanism no other investment migration program currently offers.
Two categories:
| Category | Investment | Investment period | Minimum residency |
|---|---|---|---|
| Growth Category | NZD 5 million | 3 years | 21 days/year |
| Balanced Category | NZD 10 million | 5 years | 105 days/year |
Step 2 — Permanent Resident Visa New Zealand: The Foundation for Permanent Legal Status
After holding a Resident Visa for at least 2 years and meeting at least one of the eligibility criteria, an investor becomes eligible to apply for a Permanent Resident Visa.
Why the PR Visa matters so much in the dual citizenship roadmap: New Zealand’s PR Visa carries no travel conditions expiry, and once granted, imposes no ongoing residency requirement to maintain the status. This is the stable legal foundation for progressing toward New Zealand citizenship, and eventually Australian citizenship — uninterrupted by visa complications.
Step 3 — New Zealand Citizenship: The Key That Unlocks Australia
To apply for New Zealand citizenship, an investor must meet:
- At least 5 years of lawful residence in New Zealand, counted to the application date
- No more than 4 months’ absence in any given year — with total absence across the 5 years not exceeding 1,350 days
- A basic English requirement
- Passing the Life in New Zealand Test
- A clean legal record
Important: the residency period counted includes time spent on a Resident Visa — an investor doesn’t need to wait until obtaining the Permanent Resident Visa to start the clock. Residency time begins accumulating from the day the initial AIP Resident Visa is granted.
Step 4 — Special Category Visa: The Bridge to Legal Status in Australia
Once an investor holds New Zealand citizenship and enters Australia, an SCV is granted automatically at the border — no application, no fee, no waiting.
An SCV allows:
- Indefinite living, working, and studying in Australia
- Access to Medicare (Australia’s public healthcare system)
- Being treated, since 1 July 2023, as an Australian permanent resident for citizenship purposes
Worth noting: an SCV is only valid while the investor is physically present in Australia. Leaving Australia causes the SCV to lapse — but it’s automatically reissued upon re-entry. This is a fully automatic mechanism requiring no renewal.
Step 5 — Naturalizing as Australian: The Final Destination
To naturalize as an Australian citizen while holding an SCV, the residency requirements are:
- 4 years of lawful residence in Australia immediately before the application date
- No more than 12 months’ absence within any of those 4 years
- No more than 90 days’ absence in the 12 months immediately before the application date
- A basic English requirement
- A clean legal record
After naturalizing as Australian, an investor holds both New Zealand and Australian passports simultaneously — since both countries permit multiple citizenship.
Comparing the Strength of the Two Passports
Part of why this dual citizenship strategy is so highly regarded is that both passports rank among the world’s strongest:
| Metric | New Zealand passport | Australian passport |
|---|---|---|
| Henley 2026 ranking | #6 | #7 |
| Visa-free/VOA destinations | 183 | 182 |
| All of the EU (27 countries) | ✅ | ✅ |
| UK | ✅ | ✅ |
| US | ✅ | ✅ |
| Canada | ✅ | ✅ |
| Japan | ✅ | ✅ |
| Free entry to Australia | ✅ (automatic SCV) | N/A |
| Free entry to New Zealand | N/A | ✅ (visa-free) |
| Multiple citizenship permitted | ✅ | ✅ |
Holding both passports gives an investor:
- Free entry rights to 183+ destinations — covering the entire EU, UK, US, Canada, and Japan
- The right to live and work freely in both countries, unrestricted by visas
- Dual protection against geopolitical risk — if one country’s policy becomes volatile, the other passport remains
- Consular protection rights in any country with an Australian or New Zealand embassy
A 4-Year Foreign Income Tax Exemption — A Financial Advantage From Day One
One point that’s often overlooked but genuinely valuable: someone who newly becomes a New Zealand tax resident — and hasn’t been a New Zealand tax resident in the prior 10 years — is entitled to a 48-month Transitional Resident tax exemption period covering most foreign-sourced income.
During these 4 years, the following are exempt from New Zealand tax:
- Dividends from Hong Kong businesses
- Interest on bank deposits held outside New Zealand
- Rental income from Hong Kong real estate
- Most other passive income earned overseas
This gives investors an opportunity to restructure their asset holdings during the transition period without immediate tax pressure.
FAQ: The Australia-New Zealand Dual Citizenship Strategy
- Can I keep my original citizenship after obtaining New Zealand and Australian citizenship?
On New Zealand and Australia's side: both countries permit multiple citizenship — there's no requirement to renounce other citizenship upon naturalizing. But the status on your original nationality's side needs to be confirmed separately: for the Chinese nationality held by most Hong Kong permanent residents, for example, the PRC Nationality Law follows a single-nationality principle and generally doesn't recognize a Chinese citizen simultaneously holding foreign nationality, though practical application and enforcement can vary case by case. It's worth consulting a lawyer experienced in Chinese nationality law before making a citizenship decision — this shouldn't be assumed either way.
- Can a child born in New Zealand during the AIP Visa period automatically become a New Zealand citizen?
Yes — as long as at least one parent is a New Zealand permanent resident or citizen at the time of the child's birth, the child is a New Zealand citizen from birth. This is a particular advantage for families with young children, or those planning to have children during their time in New Zealand.
- Do I need to give up my rights in New Zealand while living in Australia under an SCV?
No — once granted, New Zealand's Permanent Resident Visa carries no minimum residency requirement to maintain. An investor can live in Australia for as long as they choose without losing New Zealand permanent resident status. Returning to New Zealand at any time is possible freely on a New Zealand passport.
- What if SCV policy changes in the future?
The Trans-Tasman Agreement between Australia and New Zealand has existed for over 100 years and is one of the most stable bilateral agreements in international relations history. Changing SCV arrangements would require political agreement between both governments — a scenario highly unlikely in the foreseeable future.
- Can I work in Australia during the 4-year residency accumulation period?
Yes — an SCV allows unrestricted work in Australia across any industry. An investor can continue running a business or working in Australia during these 4 years while simultaneously accumulating residency time toward citizenship eligibility.
To fully understand the Active Investor Plus Visa’s requirements and process, review New Zealand’s Active Investor Plus visa details; to explore Australia’s current investment migration options following the closure of the 188 visa, see an overview of Australia’s 2026 investment migration programs.
Accurately planning the full AIP → New Zealand citizenship → Australian naturalization roadmap requires an advisory firm with genuine legal authority in both countries — something many Hong Kong immigration consultancies simply cannot offer. John Hu Migration Consulting is one of the few firms in Hong Kong with two directly licensed immigration advisers — MARA-registered for Australia and IAA-licensed for New Zealand — and has helped more than 6,000 families relocate successfully over 17 years, giving investors a complete dual citizenship roadmap grounded in the law of both jurisdictions.
*Outcomes, processing times, and follow-on status arrangements vary by applicant background, case specifics, documentation completeness, and official approval requirements. Given the nationality-law implications involved, we recommend consulting a lawyer familiar with Hong Kong/Chinese nationality law. The above is for reference only and does not constitute a guarantee of approval, tax advice, or legal advice.*
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