ATO proposed updates to PCG 2019/1 – Transfer pricing issues related to inbound distribution arrangements

Taxpayers that fall outside their relevant low risk zone can expect some form of ongoing monitoring and compliance activity on their inbound distribution transfer pricing arrangements, as outlined by Tom Carter and Jake Outram.

The Australian Taxation Office (ATO) has released its proposed updates to Practical Compliance Guideline PCG 2019/1, which provides transfer pricing guidance for inbound distributors. The proposed changes, outlined in the draft PCG 2019/1DC, are open for comment until 13 February 2026. Key proposals include reductions in EBIT profit markers for Life Sciences and Information and communication technology sectors, a stricter definition for digital product distributors, and the removal of refer...

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Authors: Tom Carter, Jake Outram

Published Date: 12 December 2025