
Expanding offshore? Start with the tax design.
Australia is usually first, then further afield. TPTS helps New Zealand businesses choose the right structure, set transfer pricing from day one and avoid giving away more profit to a foreign tax authority than the law requires.
- 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.
- Entry structure: branch, subsidiary or distributor
- Transfer pricing policy for the new market from day one
- Funding the offshore entity
- Permanent establishment and employee mobility
- Coordination with local advisors through TPA Global
Signs it is time to talk.
New Zealand headquartered businesses opening their first or next overseas market.
- You are hiring or sending staff overseas
- You are setting up an Australian or other subsidiary
- Overseas sales are growing through local partners
- A foreign tax authority has asked questions
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.
Why does transfer pricing matter when we are the parent?
Because both tax authorities have an interest in the split of profit. Setting the policy at the start is far cheaper than defending it later, and the Australian Taxation Office is active in this area.
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.