Tax audits, disputes & rulings

Tax audits, disputes & rulings

The tax-risk environment has changed, and technology is increasing the chance of Inland Revenue (IRD) looking into your affairs.

Real-time big data and specialist software are routinely used to monitor records and transactions. Baker Tilly Staples Rodway’s tax advisors are reliable and experienced at dealing with Inland Revenue, whether you're responding to questions, need help during an audit, have commenced the disputes process or require a binding ruling to resolve a tax uncertainty.

Our services include:

Tax audits and disputes
  • Collating and presenting information requested during risk reviews, audits and basic compliance packages.
  • Drafting and submitting technical responses and formal dispute documents to address Inland Revenue queries and challenges, including responding to Notices of Proposed Adjustment.
  • Strategy and leading negotiations to obtain the best outcomes during settlement discussions and to minimise penalties.
Voluntary disclosures
  • Making a voluntary disclosure to Inland Revenue if you haven't returned the correct income. Usually, this results in no penalties charged and immunity from prosecution.
Binding rulings
  • A binding ruling is an agreement between senior and independent Inland Revenue personnel that locks down the tax effects and efficiencies of a proposed or recent transaction.
  • We can manage your binding ruling application.

Who can benefit from a binding ruling:

  • Families requiring assurance with a proposed family business transaction.
  • Parties to large transactions e.g. property or construction projects
  • Cross-border businesses using advanced pricing agreements (APA) to lock down cross-border dealings.
  • Boards of public companies and larger family companies.
Key business contracts

Binding rulings mean your suppliers, contractors, employees and customers are tax assured when dealing with your business, for example:

  • Employee share schemes
  • Multi-party projects including infrastructure construction, film and primary industry
  • Customer loyalty programs

Binding rulings lock down the tax effect of key transactions.

Boards in total control

Tax controversy is a no-go for boards of public companies and larger family companies.

Boards use binding rulings to eliminate tax risk in large or complex transactions. This “set and forget” approach enables the board to keep a keen focus on the business itself.

Multinationals doing business in NZ

Tax is in the media. Now more than ever, multinationals operating in New Zealand use binding rulings and Advance pricing agreements (APAs) to guarantee tax efficiencies and avoid possible tax controversy in the media, protecting your brand.

Family business – restructuring

Protecting family wealth for future generations can involve the transfer of substantial income-producing assets under family structures. Key tax questions arise for Inland Revenue: Dividend stripping, deemed dividends, depreciation recovery, deemed-market-value transfers, GST. A binding ruling assures the whole family and provides intergenerational tax certainty – leaving your legacy secure.


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