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

Taxpayers who fall outside their relevant low risk zone can expect some form of ongoing monitoring and compliance activity on their inbound distribution transfer pricing arrangements.

The Australian Taxation Office (ATO) has finalised the updates to Practical Compliance Guideline PCG 2019/1 Transfer pricing issues related to inbound distribution arrangements (PCG 2019/1) which outlines its compliance approach to 'inbound' Australian distributors. The final PCG 2019/1 implemented all the changes that were proposed in PCG 2019/1DC and applies to income years ending after 22 April 2026. Key changes to PCG 2019/1 Reduction of EBIT margins for certain industry sectors. The...

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Authors: Tim Keeling, Tom Carter,

Published Date: 29 April 2026