Know when you have a taxable presence.
Sales staff, warehouses, contractors and agents can all create a permanent establishment, and with it a tax filing obligation. TPTS assesses the risk and the options for managing it, in New Zealand and offshore.
- 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.
- PE risk assessment for inbound and outbound activity
- Dependent agent and service PE analysis
- New Zealand’s PE anti-avoidance rule for large multinationals
- Profit attribution to a permanent establishment
- Operating guidelines for sales and service teams
Signs it is time to talk.
Foreign businesses selling into New Zealand, and New Zealand businesses with people on the ground overseas.
- You sell into New Zealand through local staff or agents
- New Zealand employees work offshore for extended periods
- You hold stock or equipment in another country
- A tax authority has asked about your local activities
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.
Can a single employee create a permanent establishment?
Yes, depending on what they do. An employee who habitually concludes contracts, or plays the principal role leading to them, can create a dependent agent PE.
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.