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Australia: Updated guidance on transfer pricing for inbound distribution arrangements

ATO updated its transfer pricing risk-assessment framework for inbound distribution arrangements

april 22, 2026

The Australian Taxation Office (ATO) has released an update to its practical compliance guideline (PCG) 2019/1 on transfer pricing issues related to inbound distribution arrangements.

PCG 2019/1 provides the ATO’s transfer pricing risk-assessment framework for inbound distribution arrangements and has been in place since 2019. A review of the use and application of this guideline since then has resulted in the update, which aligns the guidance with recent market performance, industry observations, and ATO administrative practices.

The update also clarifies the scope of the application of the guideline.

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