Transfer pricing in New Zealand

Transfer pricing in New Zealand at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline N/A
Submission deadline upon request 30 days
Annual update required No
Official language requirements English
Potential impact of penalties N/A


New Zealand’s tax law

Rules for transfer pricing in New Zealand are based upon:

  • Income Tax Act 2007 Sections YD 5, GB 2 and GC 6 to 14
  • Tax Administration Act 1994 Section 141A-K


The transfer pricing regulations in New Zealand are fully compliant with the OECD Transfer Pricing Guidelines.


Accepted methods

Accepted methods are:

  • The comparable uncontrolled price method
  • The resale price method
  • The cost plus method
  • The profit split method
  • The transactional net margin method

Priority of methods

Rules for transfer pricing in New Zealand prescribe that the most reliable method should be used. Further more the transfer pricing regulations state that the traditional methods are preferred over the transactional methods.

Documentation requirements

Information that should be included in the documentation:

Rules for transfer pricing in New Zealand do not prescribe specifics about what should be included in the documentation. Generally, documentation should explain why the used method has been used and that the transfer prices applied by the taxpayer are in line with the arm’s length principle.


Rules for transfer pricing prescribe that all business records should be prepared in English. However, upon request it is possible to get approval or submit the documentation in another language. 

Requirements to prepare documentation annually

In New Zealand the regulations do not prescribe that documentation should be prepared annually.

Submission deadline upon request by tax authorities

Upon request of the tax authorities, a taxpayer has 30 days to submit its documentation.

Advance Pricing Agreements


In New Zealand it is possible to obtain unilateral and bilateral Advance Pricing Agreements (APA).


Rules for transfer pricing in New Zealand do not prescribe any regulations with regard to the term for which an APA can be agreed upon.


In New Zealand there are no specific transfer pricing penalty regulations in place. This means that ordinary tax penalties apply. | the global transfer pricing reference guide