Tax implications of cross-border financing - 13 February 2019 (On Demand)


The tax rules around intercompany funding into New Zealand have recently been tightened to combat certain BEPS risks from inbound financing. For example new transfer pricing, thin capitalisation and anti-hybrid rules are now in operation. This webinar will discuss the latest rules and issues to be aware of with cross-border loans and guarantees. In particular, we will cover:

  •  Changes to thin capitalisation rules 
  •  New restrictive transfer pricing rules 
  •  Type of arrangements where anti-hybrid rules come into play 
  •  Issues that IRD focus on with loans 
  •  Risk mitigation 

The webinar will consist of a mix of the latest rules as well as practical examples to illustrate key points. We will discuss some of the matters that have resulted in IRD audit and/or dispute.

Some knowledge of financing and taxation/transfer pricing are useful, but not a pre-requisite to attend this webinar. Relevant tax and transfer pricing concepts will be summarized in advance of explaining more detailed rules.


Attendees will gain an understanding of:

  • Changes to thin capitalisation rules
  • The new restrictive transfer pricing rules
  • Types of arrangement where anti-hybrid rules come into play
  • Issues that IRD focus on with loans
  • Risk mitigation


13 February 2019


This seminar is targeted at finance people in multinational companies or accountants/advisers in practice that work with foreign owned companies.


Mark Loveday, Principal, Loveday Consulting






1.25 CPD Hours

  • On Demand Event
    Complete online in your own time (Self-paced)
    • $190.00 excl. GST

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Sole practitioners

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