Transfer Pricing

Question 1

What section of the ITA defines a transfer pricing arrangement?

Answer 1

GC 6

Question 2

Is the definition of transfer pricing arrangement in section GC 6 of the ITA, very wide?

Answer 2

Yes

Question 3

Does the definition of transfer pricing arrangement in section GC 6 of the ITA include almost everything?

Answer 3

Yes

Question 4

What two words exclude receipt or retention by a company of consideration for the issuance of a share from the definition of transfer pricing arrangement?

Answer 4

Acquisition supply

Question 5

Is money received by a company for issuing shares covered by the definition of transfer pricing arrangement in section GC 6 of the ITA?

Answer 5

No

Question 6

Does the exclusion of money received by a company for issuing shares from the definition of transfer pricing arrangement under section GC 6 of the ITA, apply to fixed rate shares?

Answer 6

No

Question 7

The exclusion of money received by a company for issuing shares from the definition of transfer pricing arrangement under section GC 6 of the ITA does not apply to what kind of shares?

Answer 7

Fixed rate shares

Question 8

For the transfer pricing arrangement rules in section GC 6 of the ITA to apply does the transfer need to be between separate entities?

Answer 8

Yes

Question 9

Do the transfer pricing arrangement rules in section GC 6 of the ITA apply to transfers between a company’s head office and its branch?

Answer 9

No

Question 10

What section of the ITA governs transfers between a company’s head office and its branch?

Answer 10

YD 5

Question 11

What does section YD 5 of the ITA cover?

Answer 11

Apportionment of income partly derived in New Zealand

Question 12

What is the intended effect of section YD 5 of the ITA?

Answer 12

That net income or loss is apportioned the same as if an independent person would have if only carrying out the activities in New Zealand and dealing at arm’s length.

Question 13

What section of the ITA governs sets out the five methods for determining that transactions are arm’s length under the transfer pricing rules?

Answer 13

Section GC 5

Question 14

What section of the ITA governs sets out the five methods for determining that transactions are arm’s length under the transfer pricing rules?

Answer 14

Section GC 13

Question 15

______________- Calculation of arm’s length amounts

Answer 15

Section GC 13

Question 16

Section GC 13 - _____________ of arm’s length amounts

Answer 16

Calculation

Question 17

Section GC 13 - Calculation of ___________________

Answer 17

arm’s length amounts

Question 18

Section GC 13 - _____________________

Answer 18

Calculation of arm’s length amounts

Question 19

Five available methods

(2) The ______________ amount of consideration must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 19

arm’s length

Question 20

Five available methods

(2) The arm’s length _________________ must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 20

amount of consideration

Question 21

Five available methods

(2) The ________________________ must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 21

arm’s length amount of consideration

Question 22

Five available methods

(2) The arm’s length amount of consideration must be calculated under any 1 or a combination of—
(a) the _______________________:
(b) the resale price method:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 22

comparable uncontrolled price method

Question 23

Five available methods

(2) The arm’s length amount of consideration must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the ______________________:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 23

resale price method

Question 24

Five available methods

(2) The arm’s length amount of consideration must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the _______________:
(d) the profit split method:
(e) the comparable profits methods.

Answer 24

cost plus method

Question 25

Five available methods

(2) The arm’s length amount of consideration must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the cost plus method:
(d) the ________________:
(e) the comparable profits methods.

Answer 25

the profit split method

Question 26

Five available methods

(2) The arm’s length amount of consideration must be calculated under any 1 or a combination of—
(a) the comparable uncontrolled price method:
(b) the resale price method:
(c) the cost plus method:
(d) the profit split method:
(e) the comparable profits methods.

Answer 26

comparable profits methods