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Our double tax agreements contain a provision called the mutual agreement procedure. This allows a taxpayer to present their case for relief from excess taxation to the competent authority of a tax administration. The procedure is also referred to as a request for competent authority assistance. Most cases requiring competent authority assistance concern transfer pricing adjustments. 

John Nash, Manager (International Revenue Strategy), is New Zealand’s designated competent authority. 

Resolutions of double taxation 

Inland Revenue may either: 

  • agree with the merits of the overseas adjustment and give a corresponding downwards adjustment in New Zealand
  • seek to persuade the treaty partner to reduce or withdraw their adjustment. 

In nearly all cases, there is a successful resolution of the double taxation. 

Transfer pricing adjustments for New Zealand taxpayers 

For transfer pricing adjustments for New Zealand taxpayers, the affected associated enterprise located in a treaty country should present its case to the competent authority of that country. 

If you have a case to present, please send your details to: 

John Nash 
Manager International Revenue Strategy 
Inland Revenue 
PO Box 2198 
Wellington 6140 

For more detailed information, go to our Double taxation relief/Mutual agreement procedure guidance page.

Mutual Agreement Procedure (MAP)

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