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New Zealand: Updated compliance focus guide for multinationals reflects BEPS, Pillar Two changes

Guidance for multinationals in self-assessing their international tax and transfer pricing risk profiles

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October 7, 2024

Inland Revenue updated its compliance focus guide for multinational enterprises to reflect key changes since 2019, including the embedding of various OECD base erosion and profit shifting (BEPS) measures and the new Pillar Two global minimum tax proposals effective in New Zealand from 2025.

The updated guide emphasizes:

  • Use of analytics and intelligence from targeted questionnaires, other tax authorities, and country-by-country (CbC) reporting, in risk profiling
  • Tax governance, or lack thereof, as a key risk indicator
  • Documented support as vital to demonstrating effective management of transfer pricing and international tax risks

The guide also includes several checklists and red flag indicators designed to assist multinational groups in self-assessing their international tax and transfer pricing risk profiles.

Read an October 2024 report prepared by the KPMG member firm in New Zealand

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