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 flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran
Among those joining EY is PwC’s former international tax and transfer pricing head
The UK firm made the appointments as it seeks to recruit 160 new partners over the next two years
The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period
The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR
Tom Goldstein, who is now a blogger, is being represented by US law firm Munger, Tolles & Olson
In looking at the impact of taxation, money won't always be all there is to it
Gift this article