Transfer pricing advice built to hold up.
Practical, commercially focused transfer pricing advice for businesses operating across borders: the documentation Inland Revenue expects, pricing that reflects how your group really works, and a defensible position if questions come.
- Senior-ledA partner on every engagement
- Big 4 depthFormer leaders of NZ’s largest TP practice
- NZ and AustraliaGlobal reach through TPA Global
Why clients bring this work to TPTS.
Transfer pricing sits at the centre of everything TPTS does. The partners led the largest transfer pricing practice in New Zealand at a Big 4 firm before founding TPTS, and that depth shows in the work: economic analysis that reflects your business, documentation written for a New Zealand reader, and advice that anticipates how Inland Revenue will look at it.
Specialist, not generalist
Transfer pricing is our core practice, not a service line within a general tax team.
Senior on every engagement
A partner does the thinking, not a rotating team of juniors.
Inland Revenue know-how
Long working relationships with Inland Revenue’s transfer pricing specialists, built over decades of APAs, reviews and disputes.
Priced for the work
Fees that compete with the large firms, without the overhead.
Every part of transfer pricing.
Start with your situation.
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.
Technical developments, explained.
Transfer pricing documentation in 2026: what Inland Revenue now expects
Inland Revenue refreshed its documentation guidance on 31 March 2026. The law is the same, the tolerance is not. What New Zealand subsidiaries should do before filing.
ReadWhat is transfer pricing?
A plain-English explanation of transfer pricing, the arm’s-length principle and why Inland Revenue cares about it.
ReadWhat is an advance pricing agreement?
How an APA works, unilateral versus bilateral, and when it is worth the effort.
Read
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.