New Zealand Inland Revenue Publishes Updated Guidance on Transfer Pricing Documentation and Thin Capitalisation Rules

New Zealand Inland Revenue has published updated guidance on Transfer Pricing Documentation and Thin Capitalisation Rules, dated 31 March 2026. The guidance updates and replaces the prior versions dated 24 February 2025 and 28 April 2021, respectively.

The updates to the guidance on transfer pricing documentation include a stricter stance on compliance and penalties, along with several structural and phrasing changes. Two main changes are summarized as follows:

• In respect of inadequate do…