November 2018
Transfer pricing questionnaire:
NewZealand branches
Answer the following questions based on the latest completed tax year. You may provide separate written comments if you wish to
give clarification on any issue or identify assumptions made. Legal entity information (Questions 12-19 below) can be in the currency
of the legal entity. All other values must be in NZ dollars.
1 Name of the company
2 IRD number
(8 digit numbers start in the second box. )
3 Address
Street address
Town or city Country Postcode
4 Contact name
5 Telephone number
6 Email
7 Tax representative
8 Ultimate parent company
9 Tax residence of the
legal entity
10 Describe the principal
activities of the branch
11 Describe the principal
activities of the legal entity
e following information is required for calculating various accounting ratios for comparison purposes. If the branch is performing below
legal entity levels you may wish to provide an explanatory note.
is branch
NZ $000
Legal entity
12 Current account/equity (net assets)
13 Total assets
14 Total revenue (excluding interest)
15 Gross profit
16 Total expenses (excluding interest and expenses taken
into account in calculating gross profit)
17 Earnings before interest, tax and exceptional items
18 Gross interest expense
19 Gross interest income
e following questions relate to supplies by or to the branch either by the legal entity or by an associate. In all cases only cross-border
dealings/transactions are to be included.
Supplied to the branch
Supplied by the branch
20 Raw materials
21 Processed goods
22 Other (specify)
23 Rents, royalties, licence or franchise fees
24 Intangible property (acquired or disposed of)
Supplied to the branch
Supplied by the branch
25 Management and administration
26 Technical
27 Research and development
28 Commissions
Supplied to the branch
Supplied by the branch
29 Interest
30 Dividends
31 Insurance
32 Guarantees
33 Other (specify)
Other dealings
Supplied to the branch
Supplied by the branch
34 Reimbursement of expenses
35 Cost sharing/contribution arrangements
36 Revenue sharing arrangements
37 Other (specify)
38 Total dealings/associated party transactions
New Zealand tax legislation sets out five methods (fields 39 to 43 below) to calculate an arms length consideration for setting transfer
prices between legal entities.
e determination of income for branches is governed by section YD5 of the Income Tax Act 2007. However, the provisions of this
legislation are subject to the business profits article of the many double tax agreements New Zealand has entered into.
In general, best practice for core dealings is to look at the New Zealand business activity and use the five methods applicable to
transactions between legal entities. In the “Supplied” columns below, record the value of dealings/transactions where prices have
been confirmed by a method (the “tested dealings/transactions”). Where more than one method was used, allocate the value to the
predominant method.
Field 44 is for the value of untested dealings/transactions. e totals at field 45 must equal the totals at field 38.
Supplied to the branch
Supplied by the branch
39 Comparable uncontrolled price method
40 Resale price method
41 Cost plus method
42 Transactional profit split method
43 Transactional net margin method
44 Untested dealings/transactions
45 Total dealings/transactions
46 Has the branch provided any goods or services or anything else of value to any part of the legal entity
operating outside New Zealand or to a non-resident associated person for no consideration?
Yes No
If the answer is “Yes
provide details.
47 In computing the profit or loss of the New Zealand branch, has any part of the income or expenditure recognised involved parts of the
legal entity operating in jurisdictions or territories, or associated persons tax resident in jurisdictions or territories, where the income
of the legal entity or associated person would be taxed at a rate of 15% or less for a company having the usual tax status of a company?
Total value for all such dealings/transactions NZ $000
48 If there are a number of companies in New Zealand which, together with this branch, form a group for tax purposes, please provide a
list of the names of the other group companies below or on a separate schedule.
49 How many full time equivalent staff does this branch employ?
50 How many staff earn more than NZ$150,000 pa (including benefits)?
51 What is the debt percentage of the New Zealand group as calculated under subpart FE of the Income Tax Act 2007?
52 Has documentation been produced in support of your transfer prices/apportionment of income and
Yes No
53 Have any dealings with any part of the legal entity operating outside New Zealand or transactions with
non-resident associated persons been the subject of a tax ruling or advance pricing agreement in another
Yes No
54 Are any dealings/associated party transactions subject to advance pricing agreement in New Zealand?
Yes No
55 Name of officer providing this information
56 Position