Balance Beyond Borders.

We transform complex cross-border tax obligations into clear, defensible positions for your business. Transfer pricing intersects intricate regulatory frameworks, economic analysis, and evolving OECD guidelines — but our senior experts distill this complexity into practical solutions. We ensure your documentation and reporting stands up to scrutiny while optimising your global tax position through technically sound, commercially pragmatic approaches that tax authorities respect.

Navigating intercompany loans and financial arrangements requires specialised expertise —especially with New Zealand's Restricted Transfer Pricing (RTP) regime and Australia's strict scrutiny of related-party financing. We structure and document your cross-border debt to withstand regulatory challenges, determining defensible interest rates and terms that satisfy both tax authorities and your treasury objectives. Whether you're establishing new financing, refinancing existing arrangements, or responding to RTP requirements, our approach balances compliance with practical financial needs.

What’s a fair margin or royalty fee between your overseas entities? That’s where our benchmarking analysis comes in. We dig into industry data, compare market rates, and give you evidence-backed figures that stand up to scrutiny. It’s not about guesswork — it’s about getting it right the first time, every time.

Sometimes, audits and disagreements happen — especially when tax authorities challenge your transfer pricing. With a rock-solid track record (no adjustments, ever), we stand by you every step of the way. From clarifying the facts to providing expert witness testimony in court, our dispute resolution service keeps you protected and in control. Our partners deliver authoritative evidence and compelling explanations that strengthen your position when it matters most.