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ATO to Update Transfer Pricing Guidance and Benchmarking for Inbound Distributors by December 2025

  • The Australian Taxation Office (ATO) will update its transfer pricing guidance (PCG 2029/1) for businesses importing goods and digital services, with changes expected by December 2025.
  • Updates include refreshed profit markers and a new low-risk “white zone” for certain inbound distributors.
  • The guideline focuses on transfer pricing risks for inbound distribution arrangements involving goods and digital products/services from related foreign entities.
  • The revised framework helps businesses assess and mitigate transfer pricing risk, and clarifies the ATO’s compliance approach.
  • The guideline does not address other tax issues such as withholding tax or anti-avoidance rules.

Source: regfollower.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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