Transfer Pricing& Tax Solutions
Specialist advisory · Auckland, New Zealand

Specialist advice forcomplex cross-borderbusiness.

Transfer pricing, international tax and New Zealand corporate tax advice from a senior-led boutique firm. The partners led the largest transfer pricing practice in New Zealand at a Big 4 firm. Now they work with you directly.

Transfer pricingInternational taxCorporate tax
Mark Loveday and Ranesh Singh, PartnersMore than 55 years’ combined transfer pricing and international tax experience
New Zealand
55+years’ combined senior experience
Big 4former leaders of NZ’s largest transfer pricing practice
2 partnersdirect access, nothing delegated down
TPA Globalinternational network of specialists
NZ + AUclients on both sides of the Tasman
Scroll

You don’t need a large tax department. You need the right specialists.

TPTS is an independent boutique advisory firm. Transfer pricing is the core of the practice, supported by international tax and New Zealand corporate tax advice for groups with cross-border transactions, tax risk, compliance obligations, disputes and expansion plans. Big-firm expertise, boutique attention, and fees that compete with the large firms.

Why businesses choose TPTS
How can we help?

Start with your situation, not our service list.

Most clients come to us with a question like one of these. Choose the closest and we’ll show you the expertise that applies.

Or take the two-minute health check
Why TPTS

Big-firm expertise.
Boutique attention.

The depth of a leading practice, delivered by the two people who built it, at a scale where you always know who is doing the work.

Specialist, not generalistTransfer pricing is the centre of our practice, not a service line inside a general tax team.
Senior experience, directlyYou work with the partners who did this work at the top of a Big 4 practice. Nothing is delegated down.
Big-firm expertiseThe partners led the largest transfer pricing practice in New Zealand at a Big 4 firm, with more than 55 years’ combined experience.
Boutique relationshipResponsive, personal and commercially minded. Advice designed to work in the business, not only to satisfy a technical requirement.
Inland Revenue know-howLong working relationships with Inland Revenue’s transfer pricing specialists, built through APAs, reviews and disputes.
International capabilityMembership of TPA Global gives clients access to specialists in other jurisdictions when a matter crosses borders.
Our experience

The kind of work we do.

Anonymised examples of recent engagements. Client names are never published.

More case studies
Financial transactions

Cross-border financing arrangement

Challenge
A New Zealand subsidiary received significant funding from an offshore related party. The group’s global policy did not reflect New Zealand’s rules for related-party debt.
TPTS approach
Economic analysis of the borrower’s credit profile, pricing of the loan under New Zealand’s rules and the OECD guidance, and documentation of the arrangement.
Outcome
A defensible transfer pricing position supported by documentation that reconciles the group policy with the New Zealand result.
Disputes

Inland Revenue transfer pricing review

Challenge
Inland Revenue opened a review of a group’s related-party arrangements after a risk review questionnaire.
TPTS approach
Risk assessment of each transaction, targeted economic analysis, a technical response and direct engagement with Inland Revenue’s transfer pricing specialists.
Outcome
The matter was resolved, with documentation strengthened so the position holds for future years.
APAs

Advance pricing agreement for an inbound loan

Challenge
A significant inbound loan carried enough exposure that the group wanted certainty rather than an annual argument.
TPTS approach
Feasibility assessment, preparation of the application and economic support, then negotiation with Inland Revenue.
Outcome
An agreed position for the term of the APA, with annual reporting handled by TPTS.
Industries

Experience across the sectors that trade across borders.

TechnologySoftware, platforms and IP-rich groups with licensing and service flows.SoftwareSaaS and licence models where the value of IP and the location of DEMPE functions drive the pricing.AutomotiveImporters and distributors with group pricing, warranty and marketing arrangements.FMCG and consumer productsDistribution margins, marketing intangibles and procurement hubs.InsuranceReinsurance, captive arrangements and intra-group services.Energy and powerInfrastructure funding, related-party debt and guarantees.PharmaceuticalsLicensing, distribution and clinical cost-sharing arrangements.Industrial productsManufacturing, contract manufacturing and supply chain restructures.Financial servicesIntra-group funding, guarantees and treasury functions.TechnologySoftware, platforms and IP-rich groups with licensing and service flows.SoftwareSaaS and licence models where the value of IP and the location of DEMPE functions drive the pricing.AutomotiveImporters and distributors with group pricing, warranty and marketing arrangements.FMCG and consumer productsDistribution margins, marketing intangibles and procurement hubs.InsuranceReinsurance, captive arrangements and intra-group services.Energy and powerInfrastructure funding, related-party debt and guarantees.PharmaceuticalsLicensing, distribution and clinical cost-sharing arrangements.Industrial productsManufacturing, contract manufacturing and supply chain restructures.Financial servicesIntra-group funding, guarantees and treasury functions.
Global reach

New Zealand expertise. International reach.

TPTS is a member of TPA Global, an international network of transfer pricing and tax specialists. When a matter touches other jurisdictions, we work with people we know, so advice is coordinated rather than contradictory.

About our global network
TPA GlobalMember firm, New Zealand
Client view

Trusted by businesses navigating international complexity.

TPTS designed our international tax and transfer pricing structure when we expanded offshore, manages our compliance efficiently and helps us manage international tax and transfer pricing issues in more than 80 countries. Mark and Ranesh have also helped us handle investigations from revenue authorities around the world.

Chief Financial OfficerNew Zealand headquartered international group
Talk to a specialist

Let’s talk about your situation.

A confidential discussion with a partner costs nothing and usually tells you within half an hour whether there is something to do. Call Mark or Ranesh directly, or send a brief outline and we’ll come back to you within one business day.

Mark Loveday · Partner+64 274 899 336
Ranesh Singh · Partner+64 274 899 388
Transfer Pricing& Tax Solutions