Transfer Pricing& Tax Solutions
International tax

Cross-border payments, taxed correctly.

Dividends, interest, royalties and service fees paid across borders carry withholding obligations. TPTS advises on non-resident withholding tax, the approved issuer levy, treaty rates and the practical mechanics of getting it right.

At a glance
  • Senior-ledA partner on every engagement
  • Big 4 depthFormer leaders of NZ’s largest TP practice
  • NZ and AustraliaGlobal reach through TPA Global
What we deliver

Everything the matter needs, nothing it doesn’t.

  • NRWT on dividends, interest and royalties
  • Approved issuer levy on related and unrelated debt
  • Treaty rate eligibility and documentation
  • Withholding on cross-border services and contractors
  • Remediation of historical errors
When to get advice

Signs it is time to talk.

Any New Zealand business making payments to non-residents, and foreign groups receiving them.

  • You pay interest or royalties to an offshore related party
  • A foreign contractor or group company provides services in New Zealand
  • You are unsure whether the treaty rate applies
  • Past payments may have been under-withheld
How we work

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.

Questions clients ask

Good questions.

Does withholding tax apply to intercompany service fees?

It depends on where the services are performed and the nature of the payment. Some payments are caught by non-resident contractors’ tax or treated as royalties. We check each flow.

Talk to a specialist

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.

Mark Loveday · Partner+64 274 899 336
Ranesh Singh · Partner+64 274 899 388
Transfer Pricing& Tax Solutions