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Inland Revenue

Tax Policy

PUBLISHED 26 October 2000

Transfer pricing guidelines now available

New Zealand's transfer pricing guidelines have been finalised. They provide general guidance on the application of the arm's length principle in section GD 13 of the Income Tax Act 1994.

Inland Revenue fully endorses the positions set out in chapters 1 to 8 of the OECD's transfer pricing guidelines and proposes to follow those positions in administering New Zealand's transfer pricing rules. New Zealand's guidelines supplement the OECD guidelines by seeking to explain transfer pricing in a way that taxpayers may find more accessible than the OECD guidelines.

The final New Zealand guidelines offer no substantive changes from the draft guidelines released in October 1997 and January 2000. A new chapter at the back of the guidelines highlights the key textual changes from the draft guidelines.

The guidelines will be printed as an appendix to theTax Information Bulletin, Volume Twelve, No.10 (October 2000) (PDF 284KB). Word and PDF versions are also available.