Base Erosion and Profit Shifting

PwC’s international tax professionals have the resources, experience and local competencies to help companies like yours address your cross-border needs, including what these changes really mean for New Zealand businesses.

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) action plan were released in October 2015.

This is the first substantial co-ordinated renovation of the international tax landscape in almost a century.

As the workstream moves from policy consultation to implementation, it’s critical to now build your understanding of what the OECD’s work means for your business. Some key things to consider:

  • Does your current global operating model accurately reflect where the value is created within your business?
  • Do you have New Zealand specific transfer pricing documentation supporting the pricing of all intra-group, cross-border transactions?
  • Who has signing or negotiation authority for your business?  Where is this undertaken?
  • Do you export product offshore? Are these products or parts stored in offshore warehouses?
  • Are you aware of restructures that your global groups have undertaken in the last five to ten years?
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Addressing transparency in an ever changing tax landscape

The OECD’s action plans are in response to the ever increasing global operations of many businesses and the need to update international tax rules to keep pace with globalisation.

Although large multinational businesses were seen as the symbol for BEPS, the likely impact is expected to be wide reaching.  New Zealand businesses of all sizes will likely be affected as the measures start to become implemented. And these changes are swiftly approaching as countries turn to implementation, with some already ahead of the game.  

How PwC can help

PwC’s international tax professionals have the resources, experience and local competencies to help companies like yours address your cross-border needs, including what these changes really mean for New Zealand businesses. Our people are closely linked with our extensive global network and can provide you with the up-to-date analytical tax insight you need to achieve your business goals, both locally and globally.

With our New Zealand based international tax, transfer pricing, tax controversy, and indirect tax teams, we’re best placed to assist you with all aspects of your international taxation needs.

What are the changes in international tax?

Watch our videos to find out.


Introduction to BEPS
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Transfer pricing documentation
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Transfer pricing substance
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Interest deductibility
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Permanent Establishment
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Hybrid arrangement
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Peter Boyce

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+64 21 823 342

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+64 27 592 1392

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