New Zealand


Practice area

World TP Reviews

Transfer pricing
Bell Gully

Mathew McKay leads the transfer pricing practice at Bell Gully. Its service includes transfer pricing disputes and litigation and APAs. It assists clients with cross-border transactions and also works closely with the commercial and financial teams to access to market information. The team has built a strong connection with the local authorities in order to negotiate APAs and make competent authority adjustments. It also works with local and foreign economists and other transfer pricing experts. These experts offer access to historical market data, the application of the arm’s-length standard in different jurisdictions and negotiations with foreign tax authorities. 

Buddle Findlay

Tony Wilkinson leads the transfer pricing practice at Buddle Findlay. He has a strong reputation for advising both public and private sector clients. His practice includes corporate restructurings and acquisitions, tax disputes, inbound and outbound investments and customs and excise duty matters. The team assists clients with transfer pricing audits and disputes. 

Senior associate Brett Rawlings and Jo Giboney left the firm in 2018. 


Partner Melanie Meyer and Bart de Gouw lead the transfer pricing practice at Deloitte. This includes transfer pricing documentation, APAs and MAPs. It provides services to the middle market and works with smaller enterprises in their efforts to achieve on the global stage. It advises the New Zealand Inland Revenue Department (IRD) about the impact of BEPS actions and assists in shaping the direction of transfer pricing in New Zealand. 

In 2018, the team assisted a client with the transfer pricing audit of its restructuring, which involved the acceptance of historical market support payments. It also helped a client on a transfer pricing controversy issue with the Inland Revenue on a capital transaction. 

The firm expanded by hiring Chapple Mark and Lucy Scanlon in 2018. 

Client feedback 

“Competent and responsive.” 

“Overall very good. Strong on the documentation and relationship with local tax authorities. Tended to be slow on contact with the client and often required follow up.” 

Russell McVeagh

Brendan Brown leads the transfer pricing practice at Russell McVeagh. Other key practitioners include Fred Ward, Tim Stewart and Chris Harker. It provides services including audit, litigation and advance rulings. It has also been involved in policy development and reforms regarding BEPS matters. 

The team covers transfer pricing disputes, some of which cases have been solved under a MAP. In 2018, the team helped a financial institution on a transfer pricing dispute. The team represented the client negotiating with the Inland Revenue for an inconsistency between the restricted transfer pricing rule and a double tax agreement. The authority agreed to deal with this under the MAP. 

TP Equilibrium

Managing partner Leslie Prescott-Haar leads the transfer pricing practice at TP Equilibrium. She specialises in APAs and transfer pricing audits. Other key practitioners include Stefan Sunde and Sophie Day. It has an alliance with Duff & Phelps in order to provide better services related to valuation, risk management, corporate finance and other financial expertise. The team is also active on the transfer pricing of financial transactions, in relation to the most material Trans-Tasman financial transactions. 

The team helped a client on a transfer pricing matter including competent authorities and a MAP. In addition, it assisted some clients with a number of transfer pricing audits.