
Our expertise
Three disciplines. One specialist team.
Transfer pricing at the core, with international tax and New Zealand corporate tax advice around it. Every engagement is led by a partner.
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
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Transfer pricing
At the core of our practice.- Documentation
- Benchmarking
- Loans and guarantees
- Policy and planning
- APAs
- Disputes
- Due diligence
International tax
Cross-border decisions with confidence.- Double tax treaties
- Permanent establishment
- Withholding tax
- Cross-border financing
- Structuring and repatriation
- Expanding offshore
- Entering New Zealand
Corporate tax
Practical advice on complex matters.- Corporate tax advice
- Inland Revenue disputes
Transfer pricing
Transfer pricing advice built to hold up.
Documentation, policy, benchmarking, financial transactions, APAs and disputes.
Transfer pricing overviewTransfer pricing documentationMaster file and local file documentation that meets Inland Revenue’s 2026 expectations.Read more BenchmarkingComparable searches and economic analysis that support your pricing.Read more Financial transactionsPricing intercompany loans, guarantees and cash pooling under New Zealand’s rules.Read more Transfer pricing policyDesigning and implementing a policy that fits how your group operates.Read more Advance pricing agreementsCertainty with Inland Revenue, unilateral or bilateral.Read more Disputes and controversyRisk reviews, audits, questionnaires and dispute resolution with Inland Revenue.Read more Due diligenceTransfer pricing risk assessment for acquisitions, investments and refinancing.Read more
International tax
International tax advice for cross-border business.
Treaties, permanent establishment, withholding tax, financing and structuring.
International tax overviewDouble tax treatiesApplying New Zealand’s tax treaties to real transactions.Read more Permanent establishmentWhen activity in another country creates a taxable presence.Read more Withholding taxNRWT, AIL and the treaty rates that apply to cross-border payments.Read more Cross-border financingFunding New Zealand operations from offshore, and vice versa.Read more International structuringStructuring, cash repatriation and operating models across jurisdictions.Read more New Zealand businesses going offshoreTax planning for New Zealand groups expanding into Australia and beyond.Read more Businesses entering New ZealandEstablishing in New Zealand: structure, registration, funding and transfer pricing.Read more
Corporate tax
New Zealand corporate tax, handled by seniors.
New Zealand income tax advice, tax risk and Inland Revenue disputes.
Corporate tax overviewHow can we help?
Start with your situation.

Talk to a specialist
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.
Mark Loveday · Partner+64 274 899 336
Ranesh Singh · Partner+64 274 899 388
Transfer Pricing& Tax Solutions