Australia Tax Agency Seeks Comments on Draft Guideline on Transfer Pricing for Inbound Distribution Arrangements

The Australian Taxation Office Dec. 10 opened a consultation on Draft Practical Compliance Guideline No. PCG 2019/1DC, on transfer pricing issues related to inbound distribution arrangements. The draft guideline includes changes to: 1) ensure that profit markers for the assessment of transfer pricing risk remain current and relevant; and 2) clarify a “white zone” compliance approach to risk when the Tax Agency doesn’t have cause to use compliance resources to further review the transfer pricing outcomes of inbound distribution arrangements, with exceptions. Comments are due Feb. 13, 2026. [Australia, Australian Taxation Office, 12/10/25]

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View Draft Practical Compliance Guideline No. ...