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 2025

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

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
Gift this article