Transfer pricing

Transfer pricing is a major tax issue for multi-national businesses. With falling tax revenues it is the area of focus for Revenue Authorities worldwide. The New Zealand Inland Revenue Department have recently boosted their resources in this area, specifically looking at the following (but not limited to) transactions:

Losses (is the loss being borne by the right entity)
Thin capitalisation (both inbound and outbound, is there excess debt being attributed to operations)
All related party loans (inbound in excess of NZ$10 million, outbound all sizes)
Management fees (are all costs captured, relying on 7.5% benchmark generally not appropriate)
Guarantee fees (often not charged for guaranteeing related party positions)
Royalties (often not payable in times of economic downturn)

Businesses need to offer transparency in all aspects of intercompany pricing arrangements. Grant Thornton’s multilateral approach helps our clients comply with applicable regulations and enables them to use transfer pricing as a strategic planning tool.

Our team of transfer pricing specialists can assist with:

pricing related-party transactions
transfer pricing documentation
understanding and managing risk
planning tax-efficient international business structures and supply chains
support with Inland Revenue audits

For more information about Grant Thornton’s transfer pricing services, please contact:

Greg Thompson
National Director, Tax
T +64 (0)4 474 8500
E greg.thompson@nz.gt.com

Mike Chadwick
National Transfer Pricing Manager
T +64 (0)4 474 8500
E mike.chadwick@nz.gt.com