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New Zealand: Updated transfer pricing documentation guidance

Explains expectations for maintaining Master file and Local file documentation 

may 27, 2026

The Inland Revenue Department (IRD) on March 31, 2026, issued updated guidance on transfer pricing documentation.

The guidance explains expectations for maintaining Master file and Local file documentation aligned with the OECD transfer pricing guidelines and the arm’s length principle.

The guidance also outlines common documentation deficiencies and notes that inadequate records would increase audit exposure and may result in transfer pricing adjustments and penalties.


For more information, contact a KPMG tax professional in New Zealand:

Kim Michael | kimmichael@kpmg.co.nz

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