When Inland Revenue asks, answer well.
From the first questionnaire to the disputes process, TPTS manages transfer pricing controversy with Inland Revenue, drawing on decades of large disputes and long working relationships with its transfer pricing specialists.
- 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.
- Response strategy for questionnaires, risk reviews and information requests
- Technical responses and supporting economic analysis
- Representation in meetings with Inland Revenue
- The disputes process: NOPA, response and conference stages
- Competent authority and mutual agreement procedure claims
- Settlement negotiation and APAs to close the matter going forward
Signs it is time to talk.
Any business that has received a transfer pricing questionnaire, risk review letter or audit notification.
- Inland Revenue has asked for information about related-party transactions
- A risk review has escalated to an audit
- You have received a notice of proposed adjustment
- Double taxation has arisen from an adjustment here or overseas
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.
We have received a transfer pricing questionnaire. How serious is it?
A questionnaire is a risk assessment tool rather than an audit, but how you answer shapes what happens next. It pays to get senior advice before responding.
Can an adjustment overseas be fixed in New Zealand?
Where a tax treaty applies, a competent authority claim can seek relief from double taxation. Time limits apply, so act early.
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.