Participating Advisor Programme

Inland Revenue has introduced the Participating Advisor programme as part of its broader focus on tax governance and risk management for significant enterprises. This initiative recognises the value of independent, high-quality reviews conducted by approved advisors, such as PwC, to help businesses demonstrate robust tax systems, processes, and controls. The programme is designed to provide both businesses and Inland Revenue with greater confidence in tax compliance, while also streamlining compliance activities for those who participate.

In this Tax Tips, we discuss the Participating Advisor programme in more detail. 

Who Can Benefit?

Currently, the Participating Advisor programme is available exclusively to significant enterprises, being entities or groups with annual turnover of at least $30 million or 50+ employees. This aligns with Inland Revenue’s ongoing focus on larger, more complex organisations, where the scale and diversity of operations can increase tax risk and the need for strong tax governance.

Scope of Participating Advisor Reviews

Participating Advisor reviews are targeted and practical, focusing on key areas of tax risk and compliance in relation to Tax Governance, GST, PAYE and FBT. The programme focuses on processes and controls but excludes technical tax positions.  

It is important to note that these reviews do not cover transfer pricing, income tax, or provide opinions on technical tax positions. 

How the Programme Works

1. Voluntary Participation

Engaging in a Participating Advisor review is entirely at the taxpayer’s discretion. Reviews can be initiated as part of your own tax governance policy and tax risk management plan, or in response to Inland Revenue indicating an upcoming review, audit or investigation.

2. Independent, High-Quality Reviews

Only advisors who meet Inland Revenue’s rigorous approval criteria can conduct these reviews. This includes demonstrating relevant expertise for that tax type, documented methodologies, a track record of completed reviews, and robust internal governance and controls over the work undertaken.

3. Reporting

A Participating Advisor is required to provide anonymised information on a quarterly basis to Inland Revenue. This information is ‘high-level’, and includes:

• The number of reviews undertaken in the quarter
• The aggregated approximate size and industry of those that have engaged in a Participation Advisor Review
• Those areas of tax compliance that organisations are finding more challenging.

4. Confidentiality and Control

Participating Advisor’s review reports are not automatically shared with Inland Revenue. You retain control over whether and when to provide the report to Inland Revenue, which would typically only be in response to specific queries or compliance activity.

For those businesses that have requested a Participating Advisor review in preference to Inland Revenue directly engaging in further compliance activity with them, agreement on what is provided to Inland Revenue is reached before anything is submitted. Whilst Inland Revenue reserves the right to still enquire into issues identified in the Participating Advisor review or that were out of scope, the intention is that Inland Revenue will not duplicate the work undertaken by the Participating Advisor.

5. Ongoing Relevance

A Participating Advisor review is generally considered valid for up to four years, unless there are significant changes in your business (such as new systems, policies, or key personnel).  

This means that even if you have a review undertaken simply as part of your ongoing tax risk management strategy, this should still limit or eliminate Inland Revenue interest including Inland Revenue not undertaking separate testing of what was covered in the scope of the review for a period of four years.    

Why Choose PwC for Your Review?

Opting for PwC to conduct your Participating Advisor review offers several advantages over an Inland Revenue-led review:

• Proactive Risk Management: PwC’s approach is collaborative and designed to help you identify and address tax risks before they become issues. This allows you to remediate any issues in your systems and controls in a confidential environment, rather than under the scrutiny of a regulatory review.
• Tailored, Practical Recommendations: PwC’s reviews are tailored to your business’s unique structure and risk profile, providing actionable insights and practical solutions that go beyond compliance to support your broader business objectives.
• Confidentiality and Control: With PwC, you maintain control over the review process and the resulting report. You decide if, when, and how to share the findings with Inland Revenue, giving you the opportunity to address any issues internally first.
• Board and Stakeholder Assurance: An independent review by a trusted advisor like PwC provides assurance to your Board, management, and other stakeholders that your tax governance and compliance frameworks are robust and meet best practice standards.
• Reduced Disruption: PwC’s review process is designed to minimise disruption to your business, with clear timelines and a focus on efficiency. In contrast, an Inland Revenue-led review may be more prescriptive and time-consuming.
• Support Voluntary Disclosures: If issues are identified, normal shortfall penalty rules apply, but early disclosure can mitigate penalties. 

PwC’s Role as an Accredited Participating Advisor

As an Inland Revenue accredited Participating Advisor, PwC is uniquely positioned to support significant enterprises through this programme. Our team brings deep expertise, proven methodologies, and a commitment to best practice. We can:

• Conduct comprehensive reviews tailored to your business’s size and complexity
• Provide clear, actionable recommendations to strengthen your tax controls
• Assist with documentation and Board reporting to meet Inland Revenue’s expectations
• Support you in managing interactions with Inland Revenue, including sharing review outcomes as appropriate

Summary

The Participating Advisor programme offers significant enterprises a practical, recognised pathway to demonstrate strong tax governance, reduce compliance disruption, and proactively manage tax risk. With PwC’s support, you can leverage this initiative to build confidence in your tax processes and meet Inland Revenue’s evolving expectations.

If you are a significant enterprise looking to enhance your tax governance and reduce compliance risk, consider engaging in a Participating Advisor review. Whether as part of your ongoing governance plan, or in anticipation of Inland Revenue engagement, this proactive step can provide assurance to your Board, Executive Leadership Team, and Inland Revenue.

For more information or to discuss how PwC can assist you as a Participating Advisor, please contact your usual PwC advisor.