Federal Budget 2026-27: expert insights on spending, tax reform and policy impacts. Visit hub.
While transfer pricing focuses on ensuring that related-party transactions are conducted at arm’s length for income tax purposes, customs authorities are primarily concerned with the declared value of imported goods for duty assessment. These two regulatory frameworks often apply different valuation principles, which can lead to conflicting outcomes if not properly managed.
In Australia, the Australian Border Force (ABF) and the Australian Taxation Office (ATO) operate under separate legislative regimes, yet both scrutinise intercompany pricing. The ABF requires that the customs value of imported goods reflects the actual transaction value, which may be influenced by transfer pricing adjustments. If a transfer price is later revised for tax purposes, it may trigger a requirement to amend customs declarations and potentially pay additional duty or seek refunds.
To mitigate these risks, businesses should ensure alignment between their transfer pricing policies and customs valuation methodologies. This includes maintaining robust documentation that supports the arm’s length nature of intercompany pricing and clearly explains any post-importation adjustments. The World Customs Organisation (WCO) and the OECD have issued joint guidance encouraging cooperation between tax and customs authorities, but practical implementation remains a challenge.
We can assist clients in navigating the dual compliance landscape by reviewing intercompany pricing structures, assessing customs valuation implications, and supporting proactive engagement with both the ATO and ABF. Our integrated approach helps businesses avoid double taxation, reduce the risk of penalties, and streamline cross-border operations. Whether you are importing finished goods, components, or have arrangements involving intellectual property, understanding the interplay between transfer pricing and duty is essential for effective supply chain and risk management.
The ATO’s draft PCG 2026/D1 introduces a new compliance framework for attributing risk weighted assets to Australian branches of foreign banks, reshaping thin capitalisation methodologies and documentation expectations.
PepsiCo embedded royalties, ATO Decision Impact Statement, embedded royalties Australia, royalty withholding tax, diverted profits tax, intellectual property payments, IP arrangements Australia, multinational tax Australia, ATO royalties guidance
US tariffs and IEEPA changes impacts on Australian exporters and trade compliance.
Subscribe now to be kept up-to-date with timely and relevant insights, unique to the nature of your business, your areas of interest and the industry in which you operate.
Tax Agents Disclosures
The Tax Practitioners Board maintains a register of tax agents and BAS agents. You can access and search this register here. This register includes details of the registration (and conditions if applicable) of Grant Thornton and our individual registered tax agents with whom you engage.
Your engagement letter with Grant Thornton and the Standard Terms and Conditions set out our procedures for dealing with problems or complaints. The Tax Practitioners Board also has a complaints process in relation to tax agent services as outlined on their website which can be accessed here.
Tax agents have obligations to the Tax Practitioners Board and to their clients. You also have obligations under the taxation laws and to your tax agent. Please refer to these obligations on the TPB website or the TPB’s fact sheet "Information for Clients".
Section 45 of the Tax Agent Services (Code of Professional Conduct) requires Grant Thornton to notify you if it becomes aware of certain events which have occurred in the past 5 years. Grant Thornton is not aware of any such events.