New Zealand: Transfer pricing continues to be key focus area for Inland Revenue

Tax Controversy & Dispute Resolution ()
In this article we summarise New Zealand’s response to the transfer pricing aspects of the OECD’s base erosion and profit shifting (BEPS) project, and outline the current transfer pricing focus areas of New Zealand’s tax authority (Inland Revenue).

In the recently released annual Compliance Focus document for Multinational Enterprises, Inland Revenue has again identified transfer pricing as a key focus for review in FY13/14, along with other tax planning mechanisms that could be used for BEPS.  This message is supported in the Government’s Tax Policy Work Programme (also released recently), which confirms that international tax reform over the next 18 months will focus on transfer pricing and, in particular, the potential for profit shifting using related party financing.