Australia proposes changes to its customs transfer pricing approach

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Australia proposes changes to its customs transfer pricing approach

Australian Customs has proposed changes to the administration of its customs transfer pricing, which could make importing into Australia more cumbersome.

The amendments relate to the Australian Customs transfer pricing Statement No PS2009/21 on applying for valuation advice on transfer pricing.

The changes will place a greater emphasis on valuation methodologies. While the guidance will still acknowledge transfer pricing documentation, it will also look towards valuation methods such as the identical and similar goods methods, which can sometimes be impractical for taxpayers.

Instead of the bulk-amendment process which Australian taxpayers use after a post-importation transfer pricing adjustment, the changes will require line-by-line import entry adjustments, adding to taxpayers’ compliance in this already uncertain area of transfer pricing.

Australian Customs will become stricter in its approach to transfer pricing adjustments that change the customs value of duty-free goods, or any results in a tax refund.

The list of documents that a taxpayer must supply Australian Customs will also probably increase. As the requirements stand, Australian Customs has described the types of documents that it finds useful when considering transfer pricing issues.

These changes are open to public consultation and, combined with other changes to the transfer pricing regime in Australia, they could add significantly to taxpayers’ compliance burden. It is therefore important for taxpayers to assess the practicality of these changes.

more across site & shared bottom lb ros

More from across our site

The event comes at an important moment for professionals dealing with practical realities related to this practice area
Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice
The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices
A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign
In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully
Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game
Gift this article