Funding across borders, without surprises.
Debt or equity, from where and on what terms: TPTS advises on the tax consequences of funding New Zealand operations from offshore and offshore operations from New Zealand, including thin capitalisation and interest limitation.
- Senior-ledA partner on every engagement
- Big 4 depthFormer leaders of NZ’s largest TP practice
- NZ and AustraliaGlobal reach through TPA Global
Everything the matter needs, nothing it doesn’t.
- Debt versus equity funding analysis
- Thin capitalisation and interest limitation rules
- Hybrid mismatch rules
- Withholding tax and approved issuer levy on interest
- Transfer pricing of the interest rate and guarantees
Signs it is time to talk.
Foreign groups funding New Zealand subsidiaries, and New Zealand groups funding offshore expansion.
- You are setting up or refinancing group funding
- Debt exceeds 40% of assets less non-debt liabilities
- A funding instrument is treated differently in the two countries
- You are repatriating cash from New Zealand
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.
Good questions.
What is the thin capitalisation threshold in New Zealand?
The rules compare New Zealand debt to assets, with safe harbour thresholds that depend on whether the group is inbound or outbound. We model the position before funding is put in place.
Often needed together.
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.