Practice issues 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.

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

Practice issues for transfer pricing