New Zealand


Practice area

World TP Reviews

Transfer pricing
Bell Gully

Mathew McKay is the head of the tax practice at Bell Gully. The transfer pricing team works closely with the commercial and financial teams to access to market information and assists clients with related cross-border transactions. The team also advises clients on transfer pricing disputes and litigation. Bell Gully has developed relationships with the Inland Revenue Department (IRD) responsible for negotiating APAs and making competent authority adjustments. In addition, the team has relationships with local and foreign economists and other transfer pricing experts. These professionals have the capability of offering access to historical market data, advising on the application of the arm’s length standard in different jurisdictions, inputting in negotiations with foreign tax authorities and advising on tax disputes and litigation.

Buddle Findlay

Buddle Findlay assists clients with transfer pricing audit and dispute. Tony Wilkinson is the leading partner at Buddle Findlay. He has a highly regarded practice for public and private sector clients. He has heavily involved in corporate restructurings and acquisitions, tax disputes, inbound and outbound investments and Customs and Excise duty matters.

Tony Wilkinson, Jo Giboney and Maria Clezy advised a client on a transfer pricing audit and dispute with the Inland Revenue Department (IRD). It included a historic investigation by the IRD of pricing strategies applied intra-group.

In 2017, Buddle Findlay expanded by hiring Brett Rawlings as a senior solicitor. He has been promoted to senior associate in January 2018.

Chapman Tripp

Bevan Miles is the head of the transfer pricing practice at Chapman Tripp. The team has extensive tax experience regarding international transactions, transfer pricing and tax disputes with the Inland Revenue Department. He once worked in ASB Bank where he was responsible of the tax affairs of the Commonwealth Bank of Australia’s New Zealand group. The team provides services including transfer pricing disputes and APAs. It also assists clients with compliance work that involves drafting reports.


Diana Maitland and Melanie Meyer, two partners, lead the transfer pricing team at Deloitte. The team is also supported by director Bart de Gouw. Maitland has 20 years of transfer pricing experience, including restructuring operations, completion of New Zealand-specific and global documentation and planning studies, reviewing pricing transactions and planning, defending transfer pricing documentation and tax positions, and negotiating bilateral and unilateral APAs. Deloitte provides services to the largest corporates and myriad other enterprises across New Zealand. The team is also opening up the middle market as to identifying chances to work with and support smaller corporates. The firm advises the New Zealand Inland Revenue Department (IRD) about the impact of BEPS Actions and assists to shape the direction of transfer pricing in New Zealand. 

Maitland and De Gouw represented a client negotiating an APA with IRD for a five-year term. It had significant interaction with the group and the New Zealand tax authority as the position was favorable for both parties. Elsewhere, Melanie Meyer and Andrew Button assisted a client with the protection of losses and no additional tax. The team not only helped the client remove the tax liability, but also protected $475,000 of losses carried forward by communicating with and convincing the revenue authority. 

In 2017, the firm has expanded by hiring three managers, two directors and seven associate directors. 

Client feedback

“Thorough, competent and helpful.”

Grant Thornton

Greg Thompson is the head of transfer pricing practice at Grant Thornton. The transfer pricing team has one partner and two fee earners. Thompson has more than 30 years of tax experience and assists clients with cross-border risks, structuring and strategies. The team provides practices including transfer pricing disputes, compliance, structuring and advisory. The practice also assists clients with transfer pricing documentation, and pricing related party transactions and APAs negotiation. The firm is part of the global transfer pricing network of Grant Thornton. It connects with other firms across the globe to deal with the transfer pricing issues for its clients’ work in other jurisdictions.

Russell McVeagh

Brendan Brown is the head of the transfer pricing department at Russell McVeagh. The team advises clients on audit, litigation and advance rulings. The practice includes transfer pricing disputes, of which some cases have been solved under the MAP. Russell McVeagh has been involved in the policy development and reforms in response to BEPS issues. It can provide value to clients as the reforms begin to take effect. 

Brendan Brown and Tim Stewart helped Westpac New Zealand Limited (WNZL) and Westpac Banking Corporation on all New Zealand aspects of the transactions and provided transfer pricing advice in respect of the convertible notes issued by WNZL. The case was valued at $1.25 billion.

Client feedback

“Excellent work. Very practical and mindful of a solution that works in real life. Able to connect with different areas of the business and explain very complex issues in a way that makes it understandable. Always goes the extra mile. Polite and respectful to the regulators which eased tensions.”

TP Equilibrium

Leslie Prescott-Haar is the managing director of transfer pricing at TP Equilibrium. She has more than 24 years of transfer pricing experience based in New Zealand and Australia. She also has 10 years of corporate taxation experience in the big four. The firm offers a wide range of services in relation to global supply chain strategies, global transfer pricing policy analysis, design and implementation of sustainable strategies and policies, master file and local file transfer pricing documentation, APAs and similar negotiations.. The client base of TP Equilibrium goes across various industries, international transactions and projects, involving particularly intangible property and financial transactions.

Leslie Prescott-Haar and Stefan Sunde are representing a New Zealand-headquartered group in a matter concerning a New Zealand-USA bilateral APA. The deal concerns the coverage of a financial transaction at a time of significant technical uncertainty. The supply chain restructuring also has a potential effect on the transfer pricing method application.