TIB - January 2000 appendix

This appendix to TIB Vol 12 No 1 (January 2000) contains the second part of a series of draft guidelines on New Zealand’s transfer pricing rules. The first part, issued in October 1997, contained a general overview of the framework in which transfer pricing operates. This part deals with the remaining issues covered in the OECD guidelines issued to date, namely intangible property, intra-group services and cost contribution arrangements (CCAs). Subsequent guidelines will deal with advance pricing agreements (APAs) and the application to branches of section FB 2 of the Income Tax Act 1994.

Inland Revenue fully endorses the OECD guidelines in relation to issues dealt with in this part of the guidelines. This part should be read, therefore, as supplementing the OECD guidelines, rather than superseding them. On matters not addressed in draft guidelines issued to date, Inland Revenue will continue to follow the OECD guidelines.