International tax advice for cross-border business.
Treaty advice, permanent establishment risk, withholding taxes, cross-border financing and structuring, for New Zealand groups going offshore and foreign groups coming in.
- Senior-ledA partner on every engagement
- Big 4 depthFormer leaders of NZ’s largest TP practice
- NZ and AustraliaGlobal reach through TPA Global
Why clients bring this work to TPTS.
Cross-border decisions rarely sit in one tax regime. TPTS advises on how New Zealand’s rules and its tax treaties interact with the other jurisdictions in your group, so structuring, financing and repatriation decisions are made with the full picture in view.
Treaty depth
Decades of applying New Zealand’s double tax agreements to real transactions.
Both directions
Inbound investors establishing here and New Zealand businesses expanding out.
Joined up with transfer pricing
International tax and transfer pricing advice from the same senior people, so the pieces fit.
Global reach
Offshore relationships through TPA Global for multi-country matters.
Every part of international tax.
Start with your situation.
Four steps. No surprises.
A confidential discussion
A partner listens to the situation and tells you whether there is something to do.
A clear scope and fee
Written scope, a fixed or capped fee where we can, and the partner who will do the work.
Senior analysis
The partners do the thinking: facts, economics, the law and how Inland Revenue will see it.
Advice that holds up
Documentation and advice written knowing it may one day be read by a reviewer.
Technical developments, explained.
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.
ReadWhat is transfer pricing?
A plain-English explanation of transfer pricing, the arm’s-length principle and why Inland Revenue cares about it.
ReadWhat is an advance pricing agreement?
How an APA works, unilateral versus bilateral, and when it is worth the effort.
Read
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.