Introduction

The Government of New Zealand has recently released a Cabinet paper titled “Measures to strengthen transfer pricing rules and prevent permanent establishment avoidance – a government discussion document”. That Cabinet paper acknowledges the G20/ OECD initiatives for countering base erosion and profit shifting (BEPS). The New Zealand Inland Revenue and the Treasury were consulted on the Cabinet paper.

The Cabinet paper clarifies that the above-mentioned anti-avoidance package would not affect non-resident suppliers without material physical presence in New Zealand.