Documentation that is fit for purpose.
Master file and local file documentation prepared for a New Zealand reader, supported by analysis that reflects how your business actually operates. Written to satisfy Inland Revenue, and to stand up if it is tested.
- 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.
- Local file documentation for your New Zealand entity, localised to its facts, functions and risks
- Master file preparation or review of a group master file for New Zealand use
- Functional analysis interviews with local management
- Benchmarking and economic analysis supporting each material transaction
- A review of existing group documentation against Inland Revenue’s expectations
- Annual updates and a documentation calendar aligned to your balance date
Signs it is time to talk.
New Zealand subsidiaries of foreign groups, New Zealand headquartered groups with offshore operations, and any business with material related-party transactions.
- Your group’s documentation is prepared centrally and has not been localised for New Zealand
- Cross-border related-party transactions are more than 20% of gross revenue
- You have intercompany loans above $10 million, guarantee fees, royalties or service charges
- Inland Revenue has sent a transfer pricing questionnaire or risk review letter
- Your operating model or supply chain has changed
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.
Does New Zealand require transfer pricing documentation to be filed every year?
No. Documentation is not filed with the return, but the burden of proof sits with the taxpayer, so contemporaneous documentation is what demonstrates that reasonable care was taken when the return was filed.
Our group has a master file prepared overseas. Is that enough?
Usually not on its own. Inland Revenue expects group documentation to be localised to New Zealand facts and circumstances, with local management responsible for its accuracy. We review group material and prepare the New Zealand local file around it.
What changed in 2026?
Inland Revenue refreshed its documentation guidance on 31 March 2026. The law did not change, but the guidance makes clear what it considers adequate documentation and that shortfall penalties are more likely where documentation falls short. Our 2026 guide explains what that means in practice.
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.