Transfer Pricing& Tax Solutions
+64 274 899 336 Talk to a specialist
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
Talk to a specialist Explore our expertise
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
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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
Our expertise

Three disciplines. One specialist team.

Every engagement is led by a partner. Pick the discipline closest to your question, or let us point you to it.

01

Transfer pricing

At the core of our practice.
  • Documentation
  • Benchmarking
  • Loans and guarantees
  • Policy and planning
  • APAs
  • Disputes
  • Due diligence
Explore transfer pricing 02

International tax

Cross-border decisions with confidence.
  • Double tax treaties
  • Permanent establishment
  • Withholding tax
  • Cross-border financing
  • Structuring and repatriation
  • Expanding offshore
  • Entering New Zealand
Explore international tax 03

Corporate tax

Practical advice on complex matters.
  • Corporate tax advice
  • Inland Revenue disputes
Explore corporate tax
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.

Why TPTS About the firm
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.
The partners

Hire people, not a brand.

Two partners with a combined 55-plus years in transfer pricing and international tax, both former leaders of the largest transfer pricing practice in New Zealand at a Big 4 firm.

Mark Loveday
Partner · Transfer Pricing & International Tax

Mark Loveday

30+years in corporate and international tax

Over 30 years in corporate and international tax, including 16 years as a Big 4 tax partner leading the largest transfer pricing practice in New Zealand.

Transfer pricingInternational taxFinancial transactionsAdvance pricing agreements
Full profile
Ranesh Singh
Partner · Transfer Pricing & International Tax

Ranesh Singh

20+years in transfer pricing and international tax

Over 20 years in transfer pricing and international tax, including 12 years as a Big 4 principal helping to lead the largest transfer pricing practice in New Zealand.

Transfer pricingTransfer pricing frameworksAdvance pricing agreementsCompetent authority
Full profile
TPTS Insights

What Inland Revenue expects in 2026.

Technical developments explained in plain English, and a growing library of short answers to the questions clients ask most.

All insights
New for 2026Transfer pricing6 min read

Transfer pricing documentation in 2026: what Inland Revenue now expects

Inland Revenue refreshed its documentation guidance on 31 March 2026. The law is the same, the tolerance is not. What New Zealand subsidiaries should do before filing.

Read the guide
TPTS Explains4 min read

What is transfer pricing?

A plain-English explanation of transfer pricing, the arm’s-length principle and why Inland Revenue cares about it.

Read TPTS Explains4 min read

What is an advance pricing agreement?

How an APA works, unilateral versus bilateral, and when it is worth the effort.

Read
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.
Financial transactionsTransfer pricing documentation
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.
Disputes and controversyBenchmarking
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.
Advance pricing agreementsFinancial transactions
Industries

Experience across the sectors that trade across borders.

Industries we work in
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.

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