We've published a draft update to practical compliance guideline PCG 2019/1 Transfer pricing issues related to inbound distribution arrangements. This includes updated profit marker guidance – specifically for the Life Science and Information and Communication Technology industries, reflecting current benchmarking to assess transfer pricing risk for inbound distribution arrangements
The updates also clarify the scope of the application of the PCG and Reportable tax position (RTP) reporting by introducing a white zone for certain taxpayers – the white zone category will apply to certain taxpayers, for example, those with a signed advance pricing arrangement (APA) or a recent high assurance rating.
The update to this PCG also contains a definition of inbound distributors in relation to tangible goods and digital products, and clarifies the scope of what will not be risk assessed under the PCG by explicitly excluding certain arrangements from the application of the PCG.
We encourage you to familiarise yourself with the updated PCG, which is available on our legal database, to understand your obligations.
The draft update is open for consultation until 13 February 2026. Follow the details outlined in the PCG to submit your feedback.
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