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A ‘boutique’ advisory firm specialising in all aspects of transfer pricing. We also offer international tax and New Zealand corporate tax services.

Transfer Pricing & Tax Specialist

International Tax Advisory

Transfer Pricing

Corporate Tax Advisory

Our Services

We adopt a partnership approach in offering the following services

Transfer Pricing
  • Transfer pricing documentation and other compliance services

  • Unilateral and bilateral APAs

  • Pricing cross-border financing arrangements (loans and guarantees)

  • Planning and transfer pricing policy advice

  • International tax controversy management and resolution

  • Due diligence

International Tax Advisory
  • Double tax treaty advisory:
    – Permanent establishment
    – Cross border financing
    – Structuring and cash repatriation
    – Withholding taxes

  • Establishing a business in New Zealand

  • New Zealand businesses going offshore

Corporate Tax Advisory
  • New Zealand income tax advisory 

  • Inland Revenue disputes and resolution

About Us

WE'RE MORE THAN A TAX Advisor

A ‘boutique’ advisory firm specialising in all aspects of Transfer Pricing & Corporate International Tax.

Who are we

We are a ‘boutique’ advisory firm specialising in all aspects of transfer pricing. We also offer international tax and New Zealand corporate tax services.

This firm offers substantial and broad experience with all aspects of transfer pricing, including pricing financial instruments. We also pride ourselves in having valuable working relationships with Inland Revenue transfer pricing specialists.

Our experience

Mark Loveday and Ranesh Singh are partners in the firm. We previously led the largest transfer pricing practice in New Zealand in a “big 4” firm for 10 years.

Together we have over 55 years experience in transfer pricing and international tax. TPTS offers substantial and broad experience in respect of transfer pricing, including pricing financial instruments.

Our value proposition

We have alliances with offshore professional services firms which allow us to offer our clients global transfer pricing and international tax services.

All our services are offered at competitive prices when compared to similar quality services offered by ‘Big’ firms.

Mark Loveday, Partner

Mark Loveday has over 30 years’ experience in corporate and international tax.

He was previously a tax partner in a “big 4” accounting firm for 16 years, where for most of that time, he led the largest transfer pricing practice in New Zealand and advised International and corporate tax.

Mark has considerable experience in transfer pricing matters, including assisting to establish policies, negotiating advanced pricing agreements (APAs), including an APA regarding a significant inbound loan into New Zealand and all forms of compliance.

He has assisted clients with some large transfer pricing disputes with Inland Revenue, as well as other corporate tax disputes and has very strong relationships with all key transfer pricing specialists, the Competent Authority and key people in policy advice division within Inland Revenue. 

Mark has worked with companies across most industries, including technology; software; automotive; FMCG; insurance; power distribution and pharma.

He has presented a number of transfer pricing webinars for CCH-Wolters Kluwer and authored the CCH book: Transfer pricing: A Practical Guide for New Zealand Businesses

Mark has LLB/BCom degree as well as diploma in personal financial planning. He is a practising chartered accountant and qualified as a Solicitor of the High Court of New Zealand.

He is currently Treasurer for the German New Zealand Chamber of Commerce.

Ranesh Singh, Partner

Ranesh has over 20 years experience in transfer pricing and international tax.

He was previously a principal in a “Big 4” firm for 12 years where he helped lead the largest transfer pricing practice in New Zealand.

Ranesh has been the engagement lead for transfer pricing on a number of  New Zealand’s largest companies, with particular emphasis on technology, consumer and industrial products and automotive.

He has considerable experience in transfer pricing matters, including assisting establishing transfer pricing framework and policies, negotiating APAs and making successful competent authority applications.

A particular focus in recent years has been transfer pricing controversy matters, working on some large transfer pricing disputes with Inland Revenue.

Over the years, Ranesh has built strong working relationships with key Inland Revenue transfer pricing specialists, the Competent Authority and key people in Inland Revenue’s policy division.

He has presented on a number of transfer pricing topics and written articles on transfer pricing developments.

Ranesh has a LLB/BCom degree. He is a chartered accountant and Solicitor of the High Court of New Zealand.

What Clients Say

WE'RE MORE THAN A TAX SPECIALIST

Our Company has worked with Mark & Ranesh over many years including when we expanded offshore. They designed our international tax and transfer pricing structure and have efficiently managed all compliance related issues. Both have deep and relevant insights which have helped us successfully manage investigations from various Revenue Authorities around the world. Today we are working with them at TPTS and they help us manage international tax and transfer pricing issues in more than 80 countries.

Anonymous

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