New Zealand and Australia Transfer Pricing – Recent Developments

September 29, 20210

Australia and New Zealand have a long history of trade and relations. Although they operate in distinct tax and transfer pricing systems, there is close co-operation between the tax authorities and an element of willingness to share information.

Even before BEPS, Australia has been progressive in its transfer pricing reform and its tax authority has sometimes been labelled “aggressive” in its activities to counter BEPS behaviours, resulting in some case law. New Zealand has only recently introduced BEPS related reforms, including some unusual rules on pricing inbound loans.

If you have clients with a business activity in Australia or New Zealand, generating sales in those countries, or you simply have an interest in those countries, then please register for this webinar to learn about reforms in the transfer pricing rules and practice in these countries.

Our presenters, Mark Loveday and Ranesh Singh of Transfer Pricing and Tax Solutions (“TPTS”) have recently joined the TPA Global network and will present on this topic, including the following areas:

  • An overview of each country’s transfer pricing regimes
  • Highlighting similarities and differences in the regimes
  • Areas of focus by the tax authorities
  • Documentation requirements
  • APA programmes
  • Treatment of inbound loans
  • Australian case law
  • Impact of Pillar I and II


• Mark LovedayTransfer Pricing and Tax Solutions (TPTS), TPA Global Member
• Ranesh SinghTransfer Pricing and Tax Solutions (TPTS), TPA Global Member

TPTS is a ‘boutique’ advisory firm specialising in transfer pricing and international tax in New Zealand and Australia and corporate tax advice and compliance in New Zealand. Mark Loveday and Ranesh Singh, the two partners of TPTS, have over 55 years combined experience with big 4 firms and have assisted clients across a broad range of industry sectors. TPTS is licensed with the Chartered Accountants of Australia and New Zealand

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