Australia Considers Inbound Distribution Transfer Pricing Tweaks

The Australian Taxation Office wants feedback on proposed updates to its guidelines on transfer pricing for inbound distribution arrangements—adding a new risk zone and tweaking the scope of risk assessments.

The ATO issued the draft update and consultation Wednesday, proposing introduction of a “white zone” to the current green-yellow-red zone rubric that taxpayers can use to figure out how risky their positions are.

The white zone would be for positions that are virtually risk-free, such as those covered by advance pricing agreements.

• The update includes a definition of inbound distributors in relation to tangible goods and digital products. It ...