Transfer Pricing Controversy

Deloitte has extensive controversy experience which covers both the prevention and successful resolution of disputes in New Zealand and abroad.

Transfer pricing presents many tax, legal and operational challenges. In recent times, these challenges have been compounded by new global compliance obligations and increased public transparency and scrutiny. This gives rise to many uncertainties, including the added risk of transfer pricing disputes in New Zealand or abroad. To many taxpayers the magnitude of these uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. Our expertise includes extensive experience in successfully negotiating advance pricing agreements (‘APAs’), allowing taxpayers to achieve greater certainty on their transfer pricing methods with one or more tax authorities, thereby reducing business risk. We have also assisted clients where a transfer pricing review or audit has commenced, including with negotiating with tax authorities all over the world through the mutual agreement procedure (‘MAP’). This knowledge and insight combined with recent practical experience enables Deloitte to help companies manage their transfer pricing risks, particularly the risk of double taxation, on a prospective basis.