Structures that work in every jurisdiction.
Where to hold, where to operate and how to bring cash home. TPTS advises on international structuring and cash repatriation, with the transfer pricing consequences built into the design.
- 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.
- Holding and operating structure design
- Cash repatriation: dividends, imputation and foreign dividend rules
- Controlled foreign company and foreign investment fund rules
- Restructuring and migration of entities
- Transfer pricing alignment of the new structure
Signs it is time to talk.
Groups growing beyond New Zealand and foreign groups investing here.
- You are adding entities or jurisdictions
- Profits are stranded offshore
- You are simplifying or unwinding a structure
- A transaction will change where value is created
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 we move profits to a lower-tax jurisdiction?
Profit follows where value is created, and transfer pricing rules test that. We design structures that reflect real functions, assets and risks, which is the only kind that lasts.
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.