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  • Our guidance on transfer pricing issues has been finalised

    We’ve recently issued the final version of Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralised operating models involving procurement, marketing, sales and distribution functions.

    The guidance assists taxpayers to self-assess the transfer pricing risk for certain types of purchases that they make from a related party offshore hub. This enables taxpayers to choose to enter into arrangements that will be seen as low-risk by the ATO for transfer pricing purposes, which should also reduce their costs of compliance.

    The guidance gives taxpayers increased certainty over the risk profile of their commercial activities. It will also help taxpayers to understand the ATO’s view and its likely compliance response to their transfer pricing arrangements, in particular those dealings that are at a higher risk of shifting excessive profits to a low tax jurisdiction.

    If you have an existing arrangement that falls within this schedule, we encourage you to discuss your situation with us by emailing us at

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    Last modified: 15 Oct 2018QC 57011