
Entering New Zealand with a clear tax plan.
For foreign groups establishing a New Zealand presence, TPTS advises on the entity, the funding, the registrations and the transfer pricing of the arrangements with the parent, so the local entity starts compliant.
- 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.
- Entity choice: subsidiary, branch or distributor model
- Funding and thin capitalisation
- Tax registrations and compliance set-up
- Transfer pricing of intercompany supplies, services and funding
- Permanent establishment review before you have an entity
Signs it is time to talk.
Foreign groups opening in New Zealand, including Australian groups crossing the Tasman.
- You are hiring your first New Zealand staff
- A distributor arrangement is being replaced with a subsidiary
- You are acquiring a New Zealand business
- The parent wants to fund the New Zealand operation with debt
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.
Do we need transfer pricing documentation from year one?
If there are material transactions with the parent, yes. It is far simpler to set the policy and document it from the start than to reconstruct it later.
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.