
A policy that fits how you really operate.
Transfer pricing policy design and planning for groups setting up, restructuring or growing: the right methods for each transaction, implemented so finance teams can apply them every month.
- 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.
- Policy design for new or changing intercompany arrangements
- Operating model and supply chain reviews
- Business restructuring analysis, including exit charges
- Intercompany agreements aligned to the policy
- Implementation support for finance teams and year-end adjustments
Signs it is time to talk.
Groups expanding into or out of New Zealand, and groups changing where functions, assets or risks sit.
- You are establishing a New Zealand entity or your first offshore subsidiary
- Functions, assets or risks are moving between countries
- The current policy has drifted from how the business works
- Finance cannot explain how the intercompany prices are set
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 restructuring our supply chain create transfer pricing issues?
Often, yes. Inland Revenue lists supply chain restructures that move functions, assets or risks away from New Zealand among its focus areas. The analysis needs to be done before the change, not after.
Do we need intercompany agreements?
They are strongly recommended. Agreements that match the policy and the conduct of the parties are a basic part of a defensible position.
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.