Technical developments, explained in plain English.
Guides, explainers and updates on transfer pricing, international tax and New Zealand corporate tax, written by the partners for the people who have to act on them.
- GuidesPractical, checklist-led
- TPTS ExplainsShort answers to common questions
- Tax updatesWhat changed and who it affects
Transfer pricing documentation in 2026: what Inland Revenue now expects
Inland Revenue refreshed its documentation guidance on 31 March 2026. The law is the same, the tolerance is not. What New Zealand subsidiaries should do before filing.
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What is transfer pricing?
A plain-English explanation of transfer pricing, the arm’s-length principle and why Inland Revenue cares about it.
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What is an advance pricing agreement?
How an APA works, unilateral versus bilateral, and when it is worth the effort.
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97% of NZ taxpayers to be taxed higher than in Australia under Labour.
If Labour win the New Zealand election they will impose a top individual tax rate of 39% (income over $180,000). If National win, they will not…
ReadLabour’s election 2020 tax policy
Labour have announced their policy to have a new tax band of 39% for individuals earning income over $180,000. There is no planned increase in the…
ReadFact check: How do New Zealand’s personal tax rates really compare?
Those in favour of hiking personal taxes will typically state that New Zealand’s personal tax rates are relatively low compared with other countries. Don’t fall into…
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Is New Zealand already a high taxing country?
According to recent data released by OECD (includes up to 2018 provisional data), New Zealand: Ranks below the OECD average for total taxes levied as a…
ReadWhat chance of resurrecting a land tax in New Zealand?
The Green Party policy is to have two new tax brackets at the high-income end, raising about $1.3b revenue pa. But that’s a drop in the…
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The Canadian Cameco decision – why is it relevant for transfer pricing in New Zealand?
Cameco, the Canadian uranium mining and trading giant, has successfully defended its transfer pricing position involving the establishment of an offshore trading centre in Switzerland and…
ReadHow realistic is a wealth tax in New Zealand?
The Green Party policy is to impose a new wealth tax as its main plank to fund a proposed revamp of the income support system. It’s…
ReadAre our personal tax rates high in New Zealand?
On average New Zealand workers earn just below the OECD average income (in USD) and pay a high proportion of average personal income tax. However, they…
ReadOECD digital tax project torpedoed? Where to for New Zealand?
As reported by the NY Times US has suspended talks with OECD to find a consensus reform for the international taxation of the digitised economy via…
ReadDid Google allocate excessive profits to its NZ operations?
Stuff reported that for 2019 Google NZ reported a significant increase in its reported profits and tax payable in New Zealand. Google NZ reported an operating…
ReadDigital Services Tax for NZ?
In June 2019 the Government stated its preferred approach to wait for OECD to develop its multinational solution to change the taxing rules for digitised companies,…
ReadTax treaty implications for various Covid-19 issues
The OECD Secretariat issued a short paper on 3 April analysing various tax treaty issues arising from government imposed travel and ‘lock-down’ requirements as a result…
ReadTransfer Pricing Documentation – fit for purpose?
Ensure your New Zealand transfer pricing documentation is fit for purpose Changes made last year to New Zealand’s transfer pricing rules are now in force for…
ReadTransfer Pricing & Covid-19
Since writing out our last insight (an update on BEPS 2.0) the world finds itself faced with significant change and substantial economic challenges. Whilst businesses are…
ReadUpdate on BEPS 2.0
We previously outlined an overview of how OECD’s ‘Pillar 1’ and ‘Pillar 2’ initiatives (together referred to as BEPS 2.0) would work (see Nov 2019 article). Subsequently,…
Read‘BEPS 2.0’ will not be a windfall for New Zealand
BEPS 2.0 will not be a windfall for New Zealand. The OECD estimate that their latest international tax proposals will reap US$100b additional tax in aggregate…
ReadNew Zealand is out of sync with OECD’s new guidelines on financial arrangements
OECD’s recently released “Transfer Pricing Guidance on Financial Transactions” (OECD Report) is a welcome addition to the OECD Transfer Pricing Guidelines. See our summary of the report (TPTS summary).…
ReadOECD releases its guidelines for pricing financial transactions
OECD has just released its long-awaited guidelines for pricing financial transactions (OECD report). The report is intended to form a new chapter X to the OECD…
ReadStarting a business in Australia? Don’t give most profits to the taxman!!
Recently, we have had many requests to advise on New Zealand companies starting a business in Australia. It’s certainly good to see New Zealand companies expanding…
ReadInland Revenue’s Multinational Compliance Focus & other OECD developments
Welcome to our Tax Insights for November where we cover a range of recent international tax developments (concentrating on Inland Revenue's Multinational Compliance Focus) that may…
ReadInternational tax changes ahead for ‘consumer facing’ businesses
A gigantic shake up is imminent for the international taxation of many multinational groups that use the ‘digital economy’ or are simply selling branded consumer goods.…
ReadNew Zealand’s interest limitation rules
New Zealand has enacted transfer pricing rules that may restrict the deductible interest rate on inbound cross-border related party loans - even if considered arm's length. See attached…
ReadAuthority content you can download.
Four PDF guides, emailed on request.
NZ Transfer Pricing Documentation Guide
What Inland Revenue expects in a local file, and a checklist to prepare one.
Transfer Pricing Checklist for NZ Subsidiaries
Twelve questions a finance team can answer before year-end.
International Expansion Tax Checklist
Structure, funding, people and transfer pricing before the first offshore transaction.
Intercompany Financing Checklist
Loans, guarantees and cash pooling under New Zealand’s rules.
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.