Case Study Overview

  • Client Profile: New Zealand Subsidiary of a Multinational Services & Infrastructure Enterprise
  • The Relationship: A collaborative, partner-led advisory journey supporting local leadership and global stakeholders
  • Behind the Scenes: Risk review, internal stakeholder alignment, and defensible compliance under IRD transfer pricing guidelines

Balancing local tax compliance and global corporate strategy

When the local CFO of a multinational’s New Zealand subsidiary grew concerned that intercompany transfer pricing charges from offshore related parties were not at arm's length and potentially aggressive under local IRD regulations, they reached out to RSM New Zealand.

Beyond the technical tax risk, the matter carried internal sensitivity. Navigating head-office charges requires balancing local compliance obligations with global group relationships and differing perceptions of risk.

A collaborative review and risk diagnosis

We held initial conversations with the CFO to map out their concerns, potential tax risks, and internal team dynamics. Following these discussions, we scoped a targeted review engagement examining local operations and the support received from offshore entities.

Working side by side with a highly proactive and engaging CFO allowed our team to achieve complete operational transparency. Throughout the review, our international tax advisory specialists focused on balancing internal corporate risk perceptions against external regulatory expectations.

Delivering practical clarity and ongoing alignment

Our initial assessment confirmed that while certain cross border transfer pricing risks existed, within the broader business context, they were manageable.

We collaborated with client management on how to frame the findings internally—ensuring the presentation remained technically correct, fully aligned with RSM’s professional standards, and constructive for global stakeholders. Equipped with this clarity, management is moving forward to implement our recommendations with complete confidence.

The power of being understood in international tax advisory

By combining technical tax advisory expertise with an empathetic approach to corporate governance, RSM gave client management the clarity needed to move forward with confidence. The client continues to implement our recommendations in the knowledge that their transfer pricing position is well-understood and manageable.

At RSM New Zealand, we believe effective advisory goes beyond numbers on a spreadsheet. The true power of being understood lies in listening to your concerns, navigating complex group dynamics, and delivering practical solutions that protect your enterprise.

Ready to align your global operations with local tax certainty?

Reach out to the RSM New Zealand team today. Let’s sit down, grab a coffee, and discuss how our international tax advisory specialists can support your organization.