We've published updates to Practical Compliance Guideline PCG 2019/1 Transfer pricing issues related to inbound distribution arrangements to ensure profit markers remain relevant and aligned to more recent market performance for assessing transfer pricing risk. Multinationals undertaking inbound distribution should review this guidance.
We've also clarified the scope of the application of the guideline and reportable tax position schedule by introducing a 'white zone' for certain taxpayers. For taxpayers in the white zone, such as those who recently obtained high assurance for their transfer pricing, we won't apply compliance resources to further review the transfer pricing outcomes of your inbound distribution arrangements, other than to confirm ongoing consistency with the agreed approach.
This guideline applies to income years ending after 22 April 2026 and covers both existing and new inbound distribution arrangements.
We’ll continue to review and seek feedback on any further changes and improvements to the guideline.
If you have an inbound distribution arrangement, we encourage you to review this final PCG 2019/1 to understand its impact on your transfer pricing risk profile and compliance obligations.
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