Corporates
Inland Revenue's transfer pricing guidelines
(published October 2000)
About this guide
Guide to the application of section GD 13 of New Zealand's Income Tax Act 1994. The guide provides a general overview of how the transfer pricing rules operate.
Adobe Acrobat PDF | 415kb | 79 pages
When to use this guide
The guidelines to the application of section GD13 of New Zealand's Income Tax Act 1994:
- provide a general overview of the framework within which transfer pricing operates
- discuss the documentation taxpayers should be looking to prepare if they are to evidence compliance with the arm's length principle, and
- consider the more specific areas of intangible property, intragroup services, and cost contribution arrangements.
Please note that apart from a small revision to our administrative practise for services (lifting the threshold from $100,000 to $600,000), our intention is not to further update these guidelines. Instead we are now applying the latest 2010 OECD Guidelines which are consistent with New Zealand’s transfer pricing legislation and double taxation treaties.
What you will need