Global Tax and Transfer Pricing
Our transfer pricing and international tax structuring service is designed to assist multinational enterprises in navigating the complexities of cross-border transactions and ensuring compliance with global tax regulations. We provide comprehensive solutions to optimise tax efficiency and manage risks associated with international operations.
How we can help:
Transfer Pricing Compliance
Assist in preparing robust transfer pricing documentation in accordance with OECD guidelines and New Zealand's transfer pricing rules, ensuring that cross-border transactions are conducted at arm's length.
Develop and implement transfer pricing policies that align with your business operations and strategic objectives.
Support in managing transfer pricing review and disputes, providing representation and negotiation with tax authorities.
Methodology and Analysis
Advise on the selection and application of appropriate transfer pricing methods
Conduct benchmarking studies and economic analyses to support the arm's length nature of intercompany transactions.
Evaluate and document the pricing of intangible assets, intra-group services, and financial transactions.
International Tax Structuring
Design and implement tax-efficient structures for international operations, including holding company structures, financing arrangements, and supply chain optimisation.
Advise on the implications of Base Erosion and Profit Shifting (BEPS) initiatives and ensure compliance with anti-avoidance measures.
Assist with the application of Double Tax Agreements to minimise withholding taxes and prevent double taxation.
Cross-Border Tax Planning
Provide strategic advice on cross-border mergers, acquisitions, and divestitures, ensuring tax-efficient structuring and integration.
Advise on the tax implications of entering new markets and expanding international operations.
Support in managing the tax aspects of global mobility for employees, including expatriate tax planning and compliance.
Risk Management and Dispute Resolution
Conduct risk assessments to identify potential transfer pricing and international tax exposures, developing strategies to mitigate these risks.
Assist in resolving disputes with tax authorities, leveraging our expertise in negotiation and litigation support.
Provide guidance on managing the impact of changes in international tax laws and regulations.
Advance Pricing Agreements (APAs)
Assist in negotiating and obtaining Advance Pricing Agreements with tax authorities to provide certainty and reduce the risk of future disputes.
Develop and submit APA applications, including detailed transfer pricing analyses and supporting documentation.