Treaty advice for real transactions.
New Zealand has tax treaties with its major trading partners. TPTS advises on how they apply to your transactions: residence, permanent establishment, withholding taxes, relief from double taxation and the mutual agreement procedure.
- 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.
- Treaty residence and tie-breaker analysis
- Reduced withholding rates on dividends, interest and royalties
- Relief from double taxation and foreign tax credits
- Mutual agreement procedure and competent authority claims
- Treaty implications of restructuring and cross-border services
Signs it is time to talk.
Groups with transactions between New Zealand and a treaty country, and businesses with staff or activities across borders.
- You are paying dividends, interest or royalties across a border
- Staff or contractors work in another country for extended periods
- An adjustment overseas has created double taxation
- You are unsure which country has the right to tax a transaction
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.
Does a tax treaty override New Zealand law?
Treaties are given effect in New Zealand law and generally take precedence where they apply. The detail matters, and anti-avoidance rules can still apply.
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.