Transfer Pricing of Financial Transactions

Recent developments to the OECD BEPs Actions 4 include the release of OECD Transfer Pricing Guidance on Financial Transactions and New Zealand’s introduction of a restricted transfer pricing regime to combat base erosion in relation to interest deductions. These measures have put a spotlight on intercompany cross-border financing arrangements. Our specialist transfer pricing team can assist with ensuring the structuring and pricing of intercompany financing arrangements are compliant with New Zealand’s transfer pricing rules.