{"id":147498,"date":"2026-08-13T09:18:06","date_gmt":"2026-08-13T09:18:06","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=147498"},"modified":"2026-08-13T09:18:06","modified_gmt":"2026-08-13T09:18:06","slug":"new-zealand-transfer-pricing","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/new-zealand-transfer-pricing\/","title":{"rendered":"New Zealand: Transfer Pricing"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-147498","comparative_guide","type-comparative_guide","status-publish","hentry","guides-transfer-pricing","jurisdictions-new-zealand"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Ernst &amp; Young<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2026\/08\/EY_Logo_Beam_STFWC_Stacked_RGB_OffBlack_Yellow_EN-1.jpg\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Ernst &amp; Young<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2026\/08\/EY_Logo_Beam_STFWC_Stacked_RGB_OffBlack_Yellow_EN-1.jpg\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Transfer Pricing laws and regulations applicable in New Zealand<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the legal framework (legislation, regulations or administrative guidance) governing transfer pricing in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The legal framework governing New Zealand&#8217;s transfer pricing regime is set out in the Income Tax Act 2007 (ITA 2007) and the Tax Administration Act 1994 (TAA 1994). The primary transfer pricing provisions are contained in sections GC 6 to GC 19 of the ITA 2007, which require cross-border transactions between associated parties to be conducted on arm\u2019s length terms.<\/p>\n<p>Inland Revenue has also issued a range of interpretation statements, operational guidance and other publications to assist taxpayers in applying New Zealand\u2019s transfer pricing rules in practice. These materials provide further guidance on the interpretation of the legislation and Inland Revenue\u2019s administrative approach to transfer pricing compliance.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent are the OECD Transfer Pricing Guidelines incorporated into or relied upon in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand places significant reliance on the OECD Transfer Pricing Guidelines. Section GC 6(1B) of the ITA 2007 expressly requires that New Zealand\u2019s transfer pricing rules in sections GC 6 to GC 14 be applied consistently with the 2022 OECD Transfer Pricing Guidelines.<\/p>\n<p>However, there are exceptions. Notably, sections GC 15 to GC 19 incorporate the restricted transfer pricing (RTP) rules as a domestic approach for inbound cross-border financing, which is not fully consistent with the OECD Transfer Pricing Guidelines.<\/p>\n<p>That exception aside, the overall policy intent is that where a taxpayer has correctly applied the OECD Transfer Pricing Guidelines and demonstrated compliance with the arm\u2019s length principle, there should be a reasonable degree of comfort that the taxpayer\u2019s position will also satisfy New Zealand\u2019s transfer pricing rules. As a result, the OECD Guidelines serve as the primary interpretative framework for analyzing transfer pricing issues and determining arm\u2019s length outcomes in New Zealand.<\/p>\n<p>Future iterations of the OECD Transfer Pricing Guidelines would require legislative change to be recognized as part of the New Zealand transfer pricing rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How are \u201crelated parties\u201d and \u201ccontrol\u201d defined in your jurisdiction, and how do these concepts affect the application of the arm\u2019s length principle and the scope of the transfer pricing rules?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand\u2019s transfer pricing rules apply to cross-border arrangements between \u201cassociated\u201d persons. Section YB 2 (1) of the ITA 2007 states that two companies are associated persons if a group of persons exists whose total voting interests in each company equal 50% or more, or if a group of persons exists who control both companies by any other means.<\/p>\n<p>The legislation does not define \u201ccontrol\u201d. However, it is viewed as having a broad scope to assess any management control exercised over the NZ taxpayer.<\/p>\n<p>In addition to the general rules of association, the transfer pricing rules also apply to members of a non-resident owning body that has an ownership interest in the company of 50% or more. A non-resident owning body is defined in the ITA 2007 as a group of two or more non-residents that collectively hold ownership interests in a New Zealand company and are connected through a common funding arrangement. Such companies may not be considered associated under the standard rules, but are regarded as working together and associated for transfer pricing purposes.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do transfer pricing rules apply to both cross-border and domestic transactions?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. The legislation explicitly defines a transfer pricing arrangement as a cross-border arrangement. Accordingly, purely domestic transactions are outside the scope of New Zealand\u2019s transfer pricing rules and are not subject to the arm\u2019s length provisions in sections GC 6 to GC 14. However, New Zealand has a broad anti-avoidance measure which would apply in the event of a domestic transaction being structured to minimize tax liabilities.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any exemptions or exclusions from the transfer pricing rules in your jurisdiction (for example, for small and medium\u2011sized enterprises, specific transaction types, or materiality thresholds)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand tax law does not provide any formal exemptions from the transfer pricing rules based on the size of the taxpayer or the value of the transaction. All taxpayers undertaking cross-border transactions with associated parties are required to comply with the transfer pricing rules.<\/p>\n<p>However, Inland Revenue recognizes that the level of preparing detailed transfer pricing documentation should be proportionate to the transfer pricing risk and the size of the transactions involved. Therefore, to reduce compliance costs for lower-risk taxpayers and transactions, Inland Revenue has introduced several \u201csimplification measures\u201d. These include:<\/p>\n<ul>\n<li><strong>Low value-adding intra-group services:<\/strong> Inland Revenue endorses the OECD simplification approach for low value-adding intra-group services, allowing a 5% mark-up on qualifying low value-adding services without requiring additional benchmarking. There is no transaction value threshold for this simplification measure.<\/li>\n<li><strong>Small-value related-party loans:<\/strong> For cross-border loans of up to NZD 10 million, Inland Revenue publishes an indicative interest rate margin that taxpayers may rely upon as broadly reflecting an arm\u2019s length outcome, reducing the need for formal benchmarking where comparable market data is not readily available. The NZD 10 million threshold applies to the combined sum of all cross-border associated party loans.<\/li>\n<li><strong>Foreign-owned wholesale distributors:<\/strong> For foreign-owned wholesale distributors with annual turnover below NZD 30 million, Inland Revenue considers an earnings before interest and taxes (EBIT)-to-sales ratio of at least 3% to be broadly indicative of an arm\u2019s length return. Taxpayers meeting this threshold may generally rely on this safe harbor without undertaking a detailed benchmarking analysis.<\/li>\n<\/ul>\n<p>While these measures do not constitute statutory exemptions from the transfer pricing rules, they provide practical compliance concessions and reduce the documentation burden for taxpayers presenting a lower transfer pricing risk.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any notable deviations from OECD principles in local law or practice?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand generally follows the OECD Transfer Pricing Guidelines closely. However, there are some areas where domestic legislation goes beyond or modifies the OECD approach.<\/p>\n<p>As mentioned at 2, above, one notable and unique instance is New Zealand&#8217;s RTP rules, which apply to certain cross-border related-party financing arrangements. These rules were introduced as part of New Zealand&#8217;s response to the Base Erosion and Profit Shifting (BEPS) initiatives and can limit the amount of deductible interest by applying a prescriptive approach to how the credit rating of the instrument must be determined. The RTP rules represent a unilateral approach to the application of transfer pricing on inbound financing, and do not fully align with the OECD Guidelines.<\/p>\n<p>New Zealand has also not adopted the Authorized OECD Approach (AOA) contained in the 2010 version of Article 7 of the OECD Model Convention. Instead, New Zealand continues to apply an approach based on the pre-2010 version of Article 7. This means for New Zealand tax purposes, a permanent establishment is not considered to be a separate and distinct enterprise from its head-office. This has implications for the recognition of arrangements between the head-office and the branch. For example, the internal transfer of goods and\/or services may be recognized at full market prices, but only where the goods and\/or services are of the same kind that the enterprise would normally sell to third parties. Other arrangements, such as the provision of management and administration support services, must be recognized based on actual costs with no markup. Items such as interest and royalties cannot be charged from the head-office, unless they are costs incurred from third parties and allocated to the branch.<\/p>\n<p>In addition, while Inland Revenue is aligned with the Master File and Local File report guidance included in Chapter V of the OECD Transfer Pricing Guidelines, it provides additional local guidance to meeting its expectations of \u201cadequate\u201d transfer pricing documentation:<\/p>\n<ul>\n<li><strong>Local validation:<\/strong> Inland Revenue has raised concern with transfer pricing reports prepared centrally, which assume New Zealand complies with a standard functional characterization, without validating this based on the actual operations. Inland Revenue has therefore emphasized the need to validate transfer pricing documentation with local management.<\/li>\n<li><strong>Benchmarking:<\/strong> Inland Revenue requires benchmarking studies to first consider Australian comparables. In some circumstances, it may be possible to consider US, Canadian or UK comparables, however, these will be scrutinized in detail. Inland Revenue will not place reliance on Asia-Pacific benchmarking studies other than Australia, as they do not consider Asia-Pacific economies to be comparable to New Zealand.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What transfer pricing methods are recognised under local law?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Section GC 13(2) of the ITA 2007 lists the following transfer pricing methods which are available for calculating an arm\u2019s length amount:<\/p>\n<ul>\n<li>Comparable uncontrolled price method<\/li>\n<li>Resale price method<\/li>\n<li>Cost plus method<\/li>\n<li>Transactional profit split method<\/li>\n<li>Transactional net margin method<\/li>\n<\/ul>\n<p>The legislation does not formally provide for the use of alternative methods. However, Section GC 6(1B) of the ITA 2007 notes the legislation applies consistently with the OECD transfer pricing guidelines.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a prescribed hierarchy or priority among the transfer pricing methods?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. New Zealand does not prescribe a strict hierarchy of transfer pricing methods. Taxpayers are required to select and apply the method, or combination of methods, that provides the most reliable measure of an arm\u2019s length outcome in the circumstances.<\/p>\n<p>In determining the most appropriate method, section GC 13(3) of the ITA 2007 requires consideration of:<\/p>\n<ul>\n<li>The degree of comparability between the controlled transaction and the transactions used for comparison<\/li>\n<li>The completeness and accuracy of the data relied upon<\/li>\n<li>The reliability of the assumptions used<\/li>\n<li>The sensitivity of the results to any deficiencies in the data or assumptions<\/li>\n<\/ul>\n<p>Inland Revenue&#8217;s focus is generally on whether the selected method produces the most reliable arm&#8217;s length outcome in the circumstances, rather than whether a particular method is more commonly used in practice.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How are arm\u2019s length ranges determined in your jurisdiction, and do domestic tax rules, guidelines, or case law prescribe specific statistical methodologies or calculation approaches for interquartile ranges?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not provide a specific methodology for determining arm\u2019s length ranges. Instead, the legislation and Inland Revenue guidance generally follow the OECD approach, with the focus being on arriving at the most reliable arm\u2019s length outcome based on the facts and circumstances of the case.<\/p>\n<p>In practice, Inland Revenue generally refers to the interquartile range as the arm\u2019s length range, and the interquartile range is calculated consistently with standard mathematical practice.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent are comparability adjustments permitted in your jurisdiction, and which types of adjustments are most commonly applied or rejected by tax authorities?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>While not commonly observed, New Zealand permits comparability adjustments where they improve the reliability of the transfer pricing analysis and help achieve a more accurate comparison between controlled and uncontrolled transactions. The emphasis is on whether an adjustment is reasonable, supportable and leads to a more reliable outcome. The burden of proof rests with the taxpayers to support both the adjustment and the methodology used to calculate it.<\/p>\n<p>In practice, rather than relying on comparability adjustments, Inland Revenue expects a greater emphasis on selecting more accurate comparables for benchmarking analysis. Given New Zealand\u2019s relatively small size, offshore comparability sets are reasonably common. However, the territory from where such sets are drawn is an increased area of Inland Revenue focus.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What rules apply to year end transfer pricing adjustments in your jurisdiction, particularly in relation to statutory accounting requirements and their recognition for tax purposes?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not have specific statutory accounting rules governing year-end transfer pricing adjustments. Where a taxpayer identifies that the pricing of a controlled transaction does not reflect an arm&#8217;s length outcome before its financial statements have been finalized, an accounting adjustment can generally be recorded , provided the adjustment is supportable and appropriately documented.<\/p>\n<p>For income tax purposes, New Zealand&#8217;s transfer pricing rules permit adjustments that increase taxable income or reduce deductions to align the New Zealand taxable position with an arm&#8217;s length amount. Once financial statements have been finalized, downward adjustments that reduce taxable income or increase deductions are generally not recognized unless there are exceptional circumstances, such as a genuine error or oversight, and Inland Revenue agrees to the adjustment.<\/p>\n<p>New Zealand&#8217;s transfer pricing rules focus on whether the overall outcome is arm&#8217;s length rather than requiring a specific adjustment mechanism. As a result, taxpayers may also be able to achieve an arm&#8217;s length result through adjustments to the pricing of the same transaction with the same counterparty in a preceding or subsequent income year, provided the approach is commercially supportable and consistent with the facts and circumstances.<\/p>\n<p>Where transfer pricing adjustments affect the value of imported goods, corresponding customs implications should also be considered. New Zealand operates the Provisional Values Scheme, which allows importers to declare provisional customs values where the final transfer price is not known at the time of importation. This can provide a practical mechanism for aligning transfer pricing and customs outcomes while reducing exposure to penalties and interest.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are secondary adjustments applied\/included in the legislation in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand legislation does not have any explicit references to secondary adjustments. The ITA 2007 legislates that any transfer pricing adjustments made have no effect on an obligation of the taxpayer to withhold under Part R (general collection rules) in relation to the amount.<\/p>\n<p>However, a secondary adjustment can arise in respect of the RTP rules relating to inbound cross border associated party loans. Inland Revenue has released guidance stating that, if an interest rate is required to be adjusted in order to comply with the RTP rules, the difference between the actual interest rate and the RTP interest rate can give rise to a deemed dividend. In such cases, a detailed review is required to consider the application of any tax treaty to determine the applicable withholding tax rate, as well as consideration of New Zealand\u2019s imputation credit regime.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What statutory provisions, regulations, or administrative guidance govern the transfer pricing treatment of transactions involving intangibles in your jurisdiction, including any specific references to OECD Transfer Pricing Guidelines Chapter VI?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not have specific statutory provisions or regulations dealing exclusively with intangibles, instead relying on the OECD Transfer Pricing Guidelines.<\/p>\n<p>Intangibles are a significant risk area and focus for Inland Revenue. Inland Revenue has published guidance on intangible property arrangements, with particular emphasis on identifying and valuing intangibles, determining which entity performs the relevant functions and bears the associated costs and risks, and ensuring that royalty arrangements reflect the economic contribution of the New Zealand entity. Inland Revenue has highlighted that they will look at whether any royalties have been applied using a standard global\/regional rate or whether the rate has been customized to the circumstances of the New Zealand business.<\/p>\n<p>As New Zealand does not have a comprehensive capital gains tax, there may be limited tax costs arising from the transfer of intangible assets. However, Inland Revenue has a strong focus on the transfer pricing implications of any business restructurings that involve the transfer of intangible assets out of New Zealand. This involves requiring a detailed understanding of operational changes, commercial rationale and understanding the characterization of the NZ entity before and after such restructuring.<\/p>\n<p>NZ foreign-owned taxpayers with revenue exceeding NZD 30 million are required to submit an annual International Questionnaire, which includes confirmation of any business restructuring or other material changes to the local functional profile. The data from these questionnaires is used to profile taxpayers for Inland Revenue\u2019s annual enforcement program and to design targeted campaigns (the most recent campaign focused on cross-border associated party royalties).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How does your jurisdiction apply the DEMPE concept (Development, Enhancement, Maintenance, Protection, and Exploitation) when determining entitlement to intangible\u2011related returns?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand\u2019s transfer pricing legislation explicitly refers to the OECD Transfer Pricing Guidelines 2022. Determining entitlement for intangibles and hard-to-value intangibles (\u201cHTVI\u201d) should follow the principles contained in the Guidelines. Our experience suggests that Inland Revenue respect the DEMPE concept, although a thorough and well documented analysis of all relevant parties\u2019 contributions is required.<\/p>\n<p>Inland Revenue may subject profit split analyses to close scrutiny because their application can involve significant judgement. Inland Revenue may take a substance over form approach, where legal ownership of intangible property is held offshore while economically significant activities relating to its development, enhancement or exploitation are undertaken in New Zealand.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What legal or administrative criteria determine which entity is entitled to intangible related returns (e.g., entities controlling economically significant DEMPE related risks)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand determines entitlement to intangible-related returns based on substance over form. Consistent with Chapter VI of the OECD Guidelines, the key question is which entity performs, controls and funds the economically significant activities relating to the intangible and which entity exercises control over the associated risks.<\/p>\n<p>Where a New Zealand entity performs significant DEMPE-related activities or controls key risks relating to the intangible, Inland Revenue would expect the transfer pricing outcome to reflect those contributions irrespective of where legal ownership of the intangible is held (e.g., legal ownership attracting a risk-free return, with residual returns attributing to the economic owner).<\/p>\n<p>For arrangements relating to intangibles, detailed transfer pricing documentation is crucial to support the position, including validation with local management.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does local law or administrative guidance provide specific rules for hard to value intangibles, including whether ex post outcomes may be used as presumptive evidence for testing ex ante assumptions?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not have specific domestic legislation dealing with HTVI separate from its general transfer pricing rules. Instead, the transfer pricing provisions are intended to operate consistently with the OECD Transfer Pricing Guidelines.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does local law or administrative guidance expressly recognise cost sharing or cost contribution arrangements for the development or use of intangibles, and what requirements must such arrangements meet under applicable rules?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand recognizes cost contribution arrangements (\u201cCCAs\u201d) and follows the OECD guidance in Chapter VIII. Inland Revenue&#8217;s guidance similarly acknowledges CCAs and notes that expenditure incurred under such arrangements must satisfy not only transfer pricing requirements but also the ordinary domestic tax rules relating to deductibility, capital expenditure and depreciation. While they are recognized and permitted, CCAs are not widely used in practice in New Zealand. Where a CCA involves the development of valuable intangible property, Inland Revenue will focus on whether contributions, expected benefits and any balancing payments are consistent with what independent parties would have agreed in comparable circumstances.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What transfer pricing information may be exchanged cross\u2011border, and subject to what legal conditions or limitations?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Transfer pricing information is exchanged under New Zealand&#8217;s general tax information exchange framework, including the information-gathering powers in the Tax Administration Act 1994 and the exchange of information articles contained in New Zealand&#8217;s double tax agreements (DTAs) and tax information exchange agreements (TIEAs).<\/p>\n<p>In addition, New Zealand has implemented the OECD BEPS minimum standards relating to transparency and information exchange. Under BEPS Action 5, Inland Revenue exchanges information on certain tax rulings, including cross-border unilateral advance pricing agreements (\u201cAPAs\u201d) and other unilateral transfer pricing rulings, with relevant treaty partners. Under BEPS Action 13, New Zealand participates in the international exchange of Country-by-Country Reports (CbCR) through the applicable competent authority arrangements. The information exchanged may include transfer pricing arrangements, CbCR, APAs and other information relevant to the administration of New Zealand&#8217;s international tax rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">To what extent may exchanged information be relied upon in transfer pricing assessments or litigation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Information exchanged under New Zealand&#8217;s treaty network may generally be relied upon by Inland Revenue for transfer pricing risk assessment, audits and assessments, subject to the applicable confidentiality and use restrictions. There are no known transfer pricing-specific limitations on the use of exchanged information in transfer pricing disputes or litigation. Exchanged information is used by Inland Revenue in transfer pricing risk assessment and compliance activities.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What statutory or regulatory transfer pricing documentation requirements apply in your jurisdiction (including any master file, local file, or country\u2011by\u2011country reporting obligations)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Transfer pricing documentation is required in New Zealand, but with less formality in respect of format. New Zealand operates on a self-assessment basis where the burden of proof sits with the taxpayer. The TAA 1994 requires taxpayers to maintain sufficient evidence to support positions taken in their tax return, and this is expected to be in the form of transfer pricing documentation where the taxpayer has cross border associated party arrangements. The legislation does not prescribe specific requirements for transfer pricing documentation, other than where the ITA 2007 refers explicitly to the OECD Guidelines, which outlines the master file and local file formats.<\/p>\n<p>Inland Revenue\u2019s expectation for transfer pricing documentation is generally aligned with the Master File and Local File templates included in Chapter V of the OECD Guidelines. Documentation should explain the relevant transactions, the functions performed, assets used and risks assumed by the parties, the transfer pricing method selected, and the basis for concluding that the outcome is arm&#8217;s length for the particular income year.<\/p>\n<p>New Zealand-headquartered multinational groups with annual consolidated revenue exceeding NZD 1.3 billion (equivalent to the OECD EUR 750 million threshold) are required to file a country-by-country report with Inland Revenue. New Zealand does not have a filing or notification requirement for foreign-owned groups, and will instead obtain CbCR data directly under its information sharing agreements. In this manner, Inland Revenue receives approximately 25 NZ-HQ reports, and 1,500 foreign-owned reports annually.<\/p>\n<p>New Zealand does not currently maintain a public CbC reporting regime.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Who is required to prepare transfer pricing documentation, and what thresholds or conditions trigger the obligation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not prescribe a statutory turnover threshold that automatically requires taxpayers to prepare transfer pricing documentation. Instead, the burden of proof sits with the taxpayer to determine the appropriate level of transfer pricing documentation to support each year\u2019s transfer pricing position. Inland Revenue has provided a governance checklist to assist taxpayers with identifying the nature and extent of their cross-border associated-party transactions and, where those transactions are material, to maintain more robust documentation supporting the transfer pricing position adopted.<\/p>\n<p>Inland Revenue&#8217;s documentation expectations are influenced by the nature and materiality of the relevant transactions rather than solely by the size of the taxpayer. Taxpayers involved in high-value transactions, significant related-party financing, intangible property arrangements, business restructurings or other higher-risk transactions are expected to maintain more comprehensive documentation than taxpayers undertaking routine lower-risk transactions. Inland Revenue&#8217;s governance expectations and multinational compliance initiatives emphasize taxpayers understanding their transfer pricing arrangements, the commercial rationale for those arrangements, and how transfer pricing outcomes reflect the activities undertaken in New Zealand.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the timing requirements for preparing and submitting transfer pricing documentation, and must documentation be contemporaneous?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand does not require transfer pricing documentation to be submitted with the tax authority, and is instead provided to Inland Revenue upon request during a review or audit.<\/p>\n<p>However, because the burden of proof sits with the taxpayer, transfer pricing documentation must be prepared at the time of filing the income tax return to support the transfer pricing positions taken in the tax return.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What penalties or sanctions apply for failure to prepare, maintain, or submit compliant transfer pricing documentation?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Where Inland Revenue makes a transfer pricing adjustment and considers that the taxpayer&#8217;s documentation is inadequate, shortfall penalties may apply under the TAA 1994. Depending on the circumstances, Inland Revenue may impose a lack of reasonable care penalty of 20% of the tax shortfall or, in more serious cases, a gross carelessness penalty of 40% of the tax shortfall.<\/p>\n<p>Inland Revenue may also view the lack of adequate documentation as an indication of insufficient tax governance protocols, thereby leading to expanded reviews of other tax types to identify other tax risks.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there specific transfer pricing reporting requirements in relation to the filing of the corporate tax return (e.g. specific forms on intra group transactions or special disclosures on compliance)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Foreign owned taxpayers with annual revenue of more than NZD 30 million must complete an International Questionnaire each year. This questionnaire primarily focuses on identifying potential transfer pricing risks, such as any business restructures during the year, thin capitalization, transactions with low-tax jurisdictions, the size of related party transactions relative to revenue, and whether transfer pricing documentation has been maintained.<\/p>\n<p>Taxpayers are also required to complete a BEPS disclosure form, which identifies hybrid arrangements and whether the RTP rules have been applied during the year. This form should be kept by the taxpayer and provided to Inland Revenue on request.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are advance pricing agreements (APAs) available under the laws or administrative guidance of your jurisdiction, and what is their legal basis?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Inland Revenue has a well-established APA program, which allows taxpayers to obtain certainty on the transfer pricing treatment of their cross-border related-party transactions, generally for a period of five years. As of 30 June 2026, Inland Revenue have completed 342 unilateral APAs and has invested further resources into streamlining the APA process.<\/p>\n<p>Unilateral APAs in New Zealand are technically binding rulings, where Inland Revenue is bound to abide by the terms of the ruling for the covered period. This is assuming no breaches of the terms of the agreement (including changes to the covered transactions or local operations).<\/p>\n<p>Bilateral and multilateral APAs are also available where the offshore counterparties are part of a relevant double tax treaty with New Zealand.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What types of APAs are permitted (unilateral, bilateral, and\/or multilateral), and are there any statutory or treaty based limitations on their use?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand permits unilateral, bilateral and multilateral APAs. Unilateral APAs are issued as binding rulings under domestic law, while bilateral and multilateral APAs are concluded through the competent authority procedures contained in New Zealand&#8217;s tax treaties. Inland Revenue has completed bilateral APAs with Australia, Belgium, Canada, China, India, Japan, Korea, Switzerland, the United Kingdom and the United States.<\/p>\n<p>There are no material statutory restrictions on their use, although bilateral and multilateral APAs require an applicable treaty framework and the participation of the relevant foreign competent authority.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the safe harbour rules or simplified measures available for certain transactions or taxpayers, if any?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Inland Revenue recognizes the need to balance the cost of tax compliance with the level of tax risk. Therefore, to reduce compliance costs for lower-risk taxpayers and transactions, Inland Revenue has introduced several simplification measures. These include:<\/p>\n<ul>\n<li><strong>Low value-adding intra-group services:<\/strong> Inland Revenue endorses the OECD simplification approach for low value-adding intra-group services, allowing a 5% mark-up on qualifying low value-adding services without requiring additional benchmarking. There is no transaction value threshold for this simplification measure.<\/li>\n<li><strong>Small-value related-party loans:<\/strong> For cross-border loans of up to NZD 10 million, Inland Revenue publishes an indicative interest rate margin that taxpayers may rely upon as broadly reflecting an arm\u2019s length outcome, reducing the need for formal benchmarking where comparable market data is not readily available. The NZD 10 million threshold applies to the combined sum of all cross-border associated party loans.<\/li>\n<li><strong>Foreign-owned wholesale distributors:<\/strong> For foreign-owned wholesale distributors with annual turnover below NZD 30 million, Inland Revenue considers an EBIT-to-sales ratio of at least 3% to be broadly indicative of an arm\u2019s length return. Taxpayers meeting this threshold may generally rely on this safe harbor without undertaking a detailed benchmarking analysis.<\/li>\n<\/ul>\n<p>It should be noted that transfer pricing documentation is still required when applying the above simplification measures. This should include a functional analysis that demonstrates eligibility to rely on the simplification measures. The simplification measures largely apply to reduce the level of benchmarking required to support the transfer pricing arrangements.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How has the nature of transfer pricing audits evolved in your jurisdiction over the past two to three years\u2014more targeted, or more expansive and data driven?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Transfer pricing enforcement by Inland Revenue has become both more expansive (i.e., more risk reviews and audits) and detailed (i.e., more targeted). Inland Revenue&#8217;s transfer pricing team has doubled in size over the last two years, recruiting senior specialists from Big Four and internally. Transfer pricing risk assessment by Inland Revenue is much more data driven following the completion of a significant business transformation software program. As a result, Inland Revenue has become noticeably more active over the last two to three years, with cases progressing from risk review to formal audit more quickly than in the past.<\/p>\n<p>Inland Revenue&#8217;s multinational compliance program draws on a wide range of information sources, including CbCR, transfer pricing documentation, customs data, the International Questionnaire, information exchanged under international agreements, and intelligence gathered through other regulatory channels.<\/p>\n<p>Inland Revenue has also adopted a more governance-focused approach through targeted transfer pricing campaigns, including a recent review of arrangements involving intangible property.<\/p>\n<p>Inland Revenue is increasingly giving more attention to transfer pricing documentation that has been prepared centrally and does not reflect the local nuances of the New Zealand business. The use of Asia-Pacific regional benchmarking studies is also becoming routinely rejected under audit.<\/p>\n<p>A notable trend is the extent to which Inland Revenue integrates multiple data sources into its risk assessment process before commencing an audit. Taxpayers are often unaware that Inland Revenue is reviewing their transfer pricing affairs, until a letter is received confirming either further review or no further action. Where concerns are identified, reviews are often highly focused on particular risk areas, such as cross-border financing, distribution arrangements, business restructurings and intangible-related returns. Once a taxpayer is identified as exhibiting high- risk characteristics, Inland Revenue has shown a willingness to move beyond high-level information gathering and move into a detailed transfer pricing review or audit.<\/p>\n<p>It should be noted that the standard time bar is four years for most tax types (i.e., tax years are generally considered closed four years after the tax return is filed). However, this can be extended to seven years for transfer pricing cases, allowing Inland Revenue significantly more time to undertake a detailed review. The seven-year time bar applies if Inland Revenue notifies the taxpayer of the extension within the first four years of filing the relevant income tax return.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How developed is domestic case law, and does it meaningfully shape practice, or are outcomes still driven primarily by tax authorities?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>New Zealand&#8217;s transfer pricing jurisprudence is still developing, with limited domestic case law available. While the courts have considered numerous international tax and cross-border financing disputes, there have been comparatively few reported decisions dealing directly with transfer pricing methodologies or the detailed application of the arm&#8217;s length principle. As a result, there is a more limited body of judicial guidance available to taxpayers and advisors on transfer pricing issues than in many other OECD jurisdictions.<\/p>\n<p>Transfer pricing positions are therefore assessed primarily by reference to the statutory framework in Subpart GC of the ITA 2007, Inland Revenue guidance and the OECD Transfer Pricing Guidelines, which are expressly incorporated into New Zealand&#8217;s transfer pricing rules. Inland Revenue also plays a significant role through its compliance programs, operational guidance, audit activity, advance pricing agreement (APA) program and participation in mutual agreement procedure (MAP) cases.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What types of transactions or structures (e.g., IP migration, platform contributions, financing, residual profit allocations) have most frequently triggered transfer pricing adjustments or disputes with the tax authority?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Transfer pricing disputes in New Zealand most commonly arise in relation to cross-border financing arrangements, business restructurings and the movement of intangible property. These areas typically involve significant judgement around pricing, risk allocation and the appropriate distribution of returns between group members.<\/p>\n<p>Cross-border financing remains a key area of scrutiny from Inland Revenue. Cross-border related party funding, particularly where the borrower is a New Zealand resident, continues to attract significant attention.<\/p>\n<p>Inland Revenue has identified business restructurings and supply-chain realignments as important risk areas, particularly where functions, assets or risks are transferred offshore and the resulting allocation of profits appears inconsistent with the economic activities undertaken in New Zealand. Similar concerns arise in relation to intellectual property arrangements, including royalty payments, IP migrations and structures where legal ownership of intangibles is not supported by the relevant value-creating activities.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Looking five years ahead, which development is likely to reshape transfer pricing practice most profoundly in your jurisdiction\u2014digital business models, fiscal and political pressure on tax authorities, administrative capacity, or other structural changes?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Similar to many jurisdictions, New Zealand is under fiscal pressure and competes with other jurisdictions to secure tax revenue from multinationals. Inland Revenue has been provided with additional resources to increase its focus on compliance.<\/p>\n<p>In this context, the development most likely to reshape transfer pricing practice in New Zealand is the continued expansion of tax authority visibility over multinational group activities through information reporting, data analytics and international exchange mechanisms. Inland Revenue already has access to a significant volume of cross-border tax information through CbCR, exchange of information agreements and other OECD-led transparency initiatives, and this trend is likely to continue as global tax reporting frameworks become more sophisticated.<\/p>\n<p>Greater access to data is likely to allow Inland Revenue to identify potential transfer pricing risks earlier and undertake more targeted reviews of taxpayers whose outcomes differ from industry norms.<\/p>\n<p>In the context of a global landscape that is becoming more divergent, with tax authorities increasingly taking more unilateral positions, this is likely to result in additional disputes. Offshore developments, such as territories increasingly asserting a right to withholding tax on outbound payments, are likely to further drive this trend.<\/p>\n<p>As Inland Revenue obtains more granular information and develops increasingly sophisticated risk assessment capabilities, taxpayers may face more detailed scrutiny of positions that historically may not have attracted significant attention. This does not necessarily imply a more aggressive enforcement environment, but rather a more informed and targeted one.<\/p>\n<p>Dispute prevention and certainty mechanisms are likely to become increasingly important. New Zealand already has an established APA program and access to MAP under its treaty network, and both mechanisms may play a larger role as taxpayers seek certainty over complex cross-border arrangements before disputes emerge or escalate. For many multinational groups, the strategic focus may shift from defending positions after an audit to obtaining greater certainty at an earlier stage through proactive engagement with Inland Revenue, with this proactive approach being actively encouraged by Inland Revenue.<\/p>\n<p>&nbsp;<\/p>\n<p><em>The views reflected in this article are the views of the authors and do not necessarily reflect the views of the global EY organization or its member firms<\/em><\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">5859<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/147498","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=147498"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}