Intercompany financing, priced properly.
Cross-border loans, guarantees and cash pooling are the transactions Inland Revenue looks at most closely. TPTS prices them with an understanding of both the OECD approach and New Zealand’s own rules for related-party debt.
- 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.
- Interest rate pricing for inbound and outbound related-party loans
- Guarantee fee analysis
- Application of New Zealand’s restricted transfer pricing rules for cross-border related-party loans
- Thin capitalisation and interest limitation interaction
- Documentation of financing arrangements
- APA strategy for significant loans
Signs it is time to talk.
New Zealand entities funded by offshore related parties, and New Zealand groups lending to offshore subsidiaries.
- A related-party loan into New Zealand exceeds $10 million
- Interest is more than 20% of EBITDA
- A parent guarantee supports third-party bank debt
- You are refinancing or restructuring group debt
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.
How does New Zealand differ from the OECD approach on loans?
New Zealand applies specific rules to cross-border related-party loans that do not always align with the OECD guidance on financial transactions. The result can differ from what a group’s global policy assumes, and in some cases can create double taxation if not managed.
Can we agree the pricing with Inland Revenue in advance?
Yes. An advance pricing agreement can cover a financing arrangement, which gives certainty for significant loans.
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.