Transfer Pricing& Tax Solutions
Transfer pricing

Benchmarking that reflects reality.

Comparable company and transaction searches, interquartile ranges and economic analysis that support the prices your group charges, prepared with the judgement that comes from decades of reviews.

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.

  • Comparable company searches for distribution, services, manufacturing and licensing arrangements
  • Interest rate and guarantee fee benchmarking for financial transactions
  • Method selection and tested-party analysis
  • Interquartile range analysis and year-end true-ups
  • Refreshes of existing benchmarks when the facts or the market change
3% / 5% / 7%EBITE indicators Inland Revenue uses for distributors, retailers and manufacturers
5%cost-plus margin on service charges above which Inland Revenue may ask questions
33%royalties as a share of EBITE that attracts attention
When to get advice

Signs it is time to talk.

Groups that need defensible support for distributor margins, service charges, royalties or intercompany interest rates.

  • Your distributor’s margin sits below the ranges Inland Revenue publishes for its risk reviews
  • A royalty, service charge or interest rate has never been tested
  • An existing benchmark is more than three years old
  • You are setting a new transfer pricing policy
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.

Why does the benchmark matter so much?

Because the arm’s-length principle is applied through comparables. A result inside a well-constructed range is far easier to defend than a price that was set without one.

Can you benchmark intercompany loans?

Yes. Interest rates and guarantee fees are benchmarked against market data, taking account of the borrower’s credit profile and New Zealand’s specific rules for cross-border related-party loans.

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