Most countries only tax the trust if the trustee is resident.
Whereas NZ only takes the residency of the settlor into account.
A New Zealand entity can have a tax rate set at zero, so technically tax is charged even though the tax charged is zero. Another country with a reciprocal tax arrangement with NZ recognises that tax has been paid in the foreign jurisdiction, even though it was zero. Therefore the other country to avoid double taxation, also charges zero tax.
