Transfer Pricing

Transfer pricing is widely accepted as one of the most significant tax issues facing multinational enterprises and revenue authorities. Inland Revenue, like most other revenue authorities throughout the world, is 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.

In 2009, we integrated our Australian and New Zealand transfer pricing practices to better enable us to service the transfer pricing needs of our Trans Tasman clients. As a combined practice we have the capability to provide both New Zealand and Australian transfer pricing solutions out of either country.

Our New Zealand transfer pricing practice is led by our full-time transfer pricing director, Cameron Smith. Cameron has over 10 years transfer pricing experience in New Zealand, Australia and the United Kingdom .

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.