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The expenditure from cost contribution arrangements must comply with transfer pricing requirements and also satisfy the regular domestic deductibility rules, such as capital expenditure and depreciation provisions. 

New Zealand's transfer pricing rules are to be applied consistently with the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations - July 2017. Guidance on cost contribution arrangements is contained in Chapter VIII of the guidelines.

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD)


We see very few material cost contribution arrangements in New Zealand.