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Talking Tax – Issue 154

Inbound distributors: new ATO guideline on transfer pricing risk framework

On 13 March 2019, the Australian Taxation Office (ATO) released a Practical Compliance Guideline PCG 2019/1 (Guideline) on its approach to identifying potential transfer pricing issues for existing and new inbound distribution arrangements involving multi-national entities (MNEs). The Guideline sets out the ATO’s framework for this compliance activity and provides useful guidance on the ATO’s perception of the risk associated with particular industries including the life sciences, information and communications technology, motor vehicle and general distributors industries.

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