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Ngā take mahi mō ngā utu whakawhiti Practice issues for transfer pricing

International
International
  • International tax for business
    • Transfer pricing
      • What transfer pricing is
      • Governance checklist for transfer pricing
      • Specialists for transfer pricing
      • Practice issues for transfer pricing
        • Advance pricing agreements
        • Branches
        • Restructuring
        • Comparability analysis
        • Contract research services
        • Controlled foreign companies
        • Cost contribution arrangements
        • Country-by-country reporting
        • Covid-19
        • Customs New Zealand
        • Transfer pricing documentation
        • Exporters
        • Cross-border financing costs
        • Intangibles
        • Losses
        • Market support payments
        • Mutual agreement procedures
        • Permanent establishment anti-avoidance rule
        • Service charges
        • Share-based costs
        • Thin capitalisation rules
      • Compliance programme for transfer pricing
      • Simplification measures for transfer pricing
      • Questionnaires for transfer pricing

Practice issues for transfer pricing cover common topics that arise in relation to transfer pricing, such as advance pricing agreements, controlled foreign companies and country-by-country reporting requirements.


Pages in this section
  • Advance pricing agreements Read about a co-operative approach to addressing transfer pricing compliance.
  • Branches Learn how business profits of branches are treated when there is a double tax agreement or when domestic rules apply.
  • Restructuring Learn what our current focus is and how to work co-operatively with us. You'll need to document major restructures and know about general anti-avoidance.
  • Comparability analysis Taking into account the practical constraints in obtaining comparable data in New Zealand and balancing compliance costs, see our expectations for a comparability analysis.
  • Contract research services Understand that you need to undertake a detailed functional analysis before considering the appropriate transfer pricing method for contract research.
  • Controlled foreign companies Make sure transfer pricing documentation is in place and that disclosure requirements for controlled foreign companies are met.
  • Cost contribution arrangements Learn how the expenditure from cost contribution arrangements must comply with transfer pricing requirements and other regular domestic deductibility rules.
  • Country-by-country reporting The OECD has published country-by-country reporting requirements and these apply to corporate groups headquartered in New Zealand and meeting a certain threshold.
  • Covid-19 The COVID-19 pandemic has created exceptional economic circumstances with significant uncertainty remaining over the depth and duration of its effects.
  • Customs New Zealand See how Customs and Inland Revenue work together in respect to period-end valuation adjustments. You may choose to invoice intercompany transactions based on budget data and apply to use provisional values.
  • Transfer pricing documentation Learn about our expectations for transfer pricing documentation and common errors to avoid.
  • Exporters Find out the transfer pricing risks we focus on for exporters, including a checklist addressing frequently asked questions.
  • Cross-border financing costs Know how to account for cross-border financings if you're New Zealand members of multinational groups or New Zealand-owned multinationals.
  • Intangibles Make sure you know how to identify and treat intangibles.
  • Losses Understand your responsibilities around documenting losses and how we focus on transfer pricing concerns that arise from unexplained tax losses.
  • Market support payments Understand your documentation and other responsibilities for market support payments and other types of non-charging transactions, such as interest-free loans.
  • Mutual agreement procedures Find out how to submit a request for competent authority assistance, also called a 'mutual agreement procedure'. Most cases requiring this concern transfer pricing adjustments.
  • Permanent establishment anti-avoidance rule Learn about the key features, risk indicators, New Zealand profit attribution rules, profit available for attribution and returning income.
  • Service charges Find out what you'll need to know about service charges, including a checklist and examples.
  • Share-based costs Make sure that you keep legal documentation and detailed calculations for share-based remuneration including for underlying service charges.
  • Thin capitalisation rules Read about the safe-harbour threshold in New Zealand, as well as 2018 amendments, common errors and when a financial arrangement between two parties may be called into question.

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