Trans-Tasman Tax Services

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Trans-Tasman Tax Services

Australian and New Zealand have always been significant trading partners. Australia is New Zealand’s second largest destination for overseas investment and Australia is the largest source of foreign direct investment in New Zealand.

WTS Australia can assist you with all your trans-Tasman transactions, whether a greenfield investment, an acquisition or disposal, capital and funding arrangements, or IPOs. We can help guide you through the increasingly complex and regulated taxation environments in both countries, and can also assist with your tax compliance obligations.

WTS Australia works with companies listed on the ASX and NZX, other corporates, private equity funds and fund managers. We collaborate closely with our clients to develop efficient, “no surprises”, value creative solutions to deliver the desired commercial outcomes over the life cycle of your trans-Tasman investments.

What do we offer?

We can assist with:

  • Technical advice and analyses
  • Permanent establishment revenue and cost allocations
  • Corporate, partnership and trust transfer pricing
  • Evaluation of pricing structures for international transactions
  • Tax authority engagement, reviews, investigations, audit defence, dispute management and resolution
  • Unilateral, bilateral and multilateral Advance Pricing Agreements (APAs) and similar Competent Authority negotiations
  • Independent reviews / second opinions including due diligence, modelling, and transaction support
  • Expert witness services
  • Litigation support, including in respect of TP, domestic controlled transactions, debt capacity and arm’s length debt analyses, IP infringements, etc.
  • Support for board decision making
  • TP compliance and process improvement
  • TP agreements, policies and governance
  • On Call TP Director and TP outsourcing partner
  • TP automation support
  • Global, regional or country-specific transfer pricing benchmarking analyses and documentation
  • Country-by-Country Reports compliant with OECD BEPS Action 13 requirements – including filing in Australia and / or New Zealand
  • Master File and Local File transfer pricing documentation compliant with OECD BEPS Action 13 requirements and / or local jurisdiction requirements, practices and nuances – including global, regional and/or local documentation
  • Australian-specific CbC Reporting Local File (including all components, i.e., Short Form, Part A and Part B) – including lodgment with the ATO
  • Risk assessment under Australian practical compliance guidelines
  • Support with Australian Reportable Tax Position schedule, International Dealings Schedule, etc
  • Support with New Zealand BEPS Disclosure Form, International Questionnaire, etc
  • Pricing of domestic controlled transactions for domestic tax law or other purposes
  • Analyses for competition law purposes
  • Analyses around debt capacity and arm’s length debt amounts
  • Debt vs. equity qualitative and quantitative analyses
  • Cost allocations
  • Market analyses
  • IP analyses for exploitation-related structuring and pricing, IP infringement disputes, financial statement impairment analyses, etc
Sam Lo Ricco
Sam Lo RiccoSpecialist Consultant | Corporate and International Tax

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We will respond to you as soon as possible.