Any 25% foreign shareholding is deemed to be a foreign controlled company.
If for example, after registering a title, there is a change of shareholding as shown by the company register, it won't be captured by the statistics, but IRD will use that as a basis for the bright-line test of transfer within 5 years (previously 2 years) and tax the parties accordingly. The value is based on Market Value to be determined by IRD.
This is made clear in the bright line test.
Yes, statistic data is distorted, but there is a tax consequence for doing that.
How would IRD find out? They are now using data mining........ upgrading their IT, temporarily disrupting their service.... but many will be invited for coffees.
IRD is well aware of this issue of people using a limited company to purchase and change their shareholding after that to some foreigners controlled ownership. The tax legislation is clear on this, it is down for IRD to catch the fish.