Transfer Pricing& Tax Solutions
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Case studies

Real matters, without the names.

Anonymised examples of how TPTS approaches transfer pricing and international tax engagements. Client names, figures and jurisdictions are withheld; the outcomes are real.

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At a glance
  • Senior-ledA partner on every engagement
  • Big 4 depthFormer leaders of NZ’s largest TP practice
  • NZ and AustraliaGlobal reach through TPA Global
Financial transactions

Cross-border financing arrangement

Challenge
A New Zealand subsidiary received significant funding from an offshore related party. The group’s global policy did not reflect New Zealand’s rules for related-party debt.
TPTS approach
Economic analysis of the borrower’s credit profile, pricing of the loan under New Zealand’s rules and the OECD guidance, and documentation of the arrangement.
Outcome
A defensible transfer pricing position supported by documentation that reconciles the group policy with the New Zealand result.
Financial transactionsTransfer pricing documentation
Disputes

Inland Revenue transfer pricing review

Challenge
Inland Revenue opened a review of a group’s related-party arrangements after a risk review questionnaire.
TPTS approach
Risk assessment of each transaction, targeted economic analysis, a technical response and direct engagement with Inland Revenue’s transfer pricing specialists.
Outcome
The matter was resolved, with documentation strengthened so the position holds for future years.
Disputes and controversyBenchmarking
APAs

Advance pricing agreement for an inbound loan

Challenge
A significant inbound loan carried enough exposure that the group wanted certainty rather than an annual argument.
TPTS approach
Feasibility assessment, preparation of the application and economic support, then negotiation with Inland Revenue.
Outcome
An agreed position for the term of the APA, with annual reporting handled by TPTS.
Advance pricing agreementsFinancial transactions
Client view

Trusted by businesses navigating international complexity.

TPTS designed our international tax and transfer pricing structure when we expanded offshore, manages our compliance efficiently and helps us manage international tax and transfer pricing issues in more than 80 countries. Mark and Ranesh have also helped us handle investigations from revenue authorities around the world.

Chief Financial OfficerNew Zealand headquartered international group
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Let’s talk about your situation.

A confidential discussion with a partner costs nothing and usually tells you within half an hour whether there is something to do. Call Mark or Ranesh directly, or send a brief outline and we’ll come back to you within one business day.

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Mark Loveday · Partner+64 274 899 336
Ranesh Singh · Partner+64 274 899 388
Transfer Pricing& Tax Solutions