Transfer pricing is widely accepted as one of the most significant tax issues facing multinational enterprises and revenue authorities. The Inland Revenue Department, like most other revenue authorities throughout the world, are giving increased scrutiny to the transfer pricing practices of enterprises that operate across multiple jurisdictions as it seeks to protect New Zealand’s tax base.
The term “transfer pricing” refers to the pricing of product, service, intellectual property, and funding transactions between members of a multinational group. In general terms, transfer pricing aims to determine the appropriate apportionment of the global profits of a multinational group across various tax jurisdictions.
Whilst transfer pricing is often seen as a compliance issue, transfer pricing can also be used as a planning tool to create value for a multinational group. Transfer pricing planning is not restricted to large multinationals. We have undertaken numerous engagements for small New Zealand based companies that have expanded offshore.
| We will work with you to identify and implement practical and defensible transfer pricing strategies that are in line with your organisation's international corporate tax planning objectives and value creation strategies. We have a global network that we can draw upon to deliver solutions that are relevant to your industry. |
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PricewaterhouseCoopers has been voted the leading transfer pricing adviser in New Zealand by the International Tax Review in the last two surveys. Our specialist transfer pricing practice is led by our full-time transfer pricing partner, Michael Bignell. Michael has been voted as the only New Zealand transfer pricing practitioner to appear in Expert Guides' 'Guide to the World's Leading Transfer Pricing Advisers' in 2007.
The services we provide include:
- preparation of transfer pricing documentation and benchmarking analyses
- negotiation of advance pricing agreements
- tax effective structuring for New Zealand multinationals operating offshore
- diagnostic reviews of group transfer pricing policies
- royalty planning and implementation
- audit defence work
- transfer pricing risk assessment review
- due diligence sign-off
