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

After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
Partner payouts could also be reduced by a fifth, it has been reported
There is no logical reason not to extend an exemption from EU CFC rules to multinationals headquartered in side-by-side jurisdictions, USCIB said
While rarely the sole driver of a combination, tax is becoming an increasingly important part of firms' efforts to keep up with client expectations
New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Gift this article