Welcome to the PCG Hub, your central resource for navigating the growing suite of Practical Compliance Guidelines shaping Australia’s transfer pricing and cross‑border tax landscape. As the ATO increases its focus on intangibles, software payments, financing arrangements and global value chains, understanding the intent, expectations and risk frameworks behind each PCG has never been more important. This hub brings together the essential guidance, insights and explanatory materials you need to stay informed, reduce uncertainty and proactively manage ATO risk across your international related‑party dealings. While the PCGs are not law, they signal how the ATO assesses behaviour, conducts reviews and prioritises audit activity.
As a boutique transfer pricing firm with deep technical expertise across Australia and the wider Asia region, Transfer Pricing Solutions recognises how critical it is for multinationals to understand these guidelines early, assess their risk profile with confidence and maintain documentation that withstands scrutiny. Whether you are managing an intangibles migration, reviewing software payments, or preparing for changes in tax governance expectations, our PCG Hub provides the clarity, structure and practical guidance you need to support strong tax positions and protect your business against unnecessary disputes.
Intangibles Migration Arrangements
Inbound Distribution and Transfer Pricing
Low-risk Payments Relating to Software Arrangements
Restructures, Thin Capitalisation & Debt Deduction Creation Rule
COMING SOON
Imported Hybrid Mismatch -
ATO Compliance Approach
COMING SOON
OECD Hybrid Mismatch Rules
COMING SOON
Projects Involving Non-Resident Owned Mobile Offshore Drilling
COMING SOON
ATO Compliance Approach to
Arm's Length Debt Test
COMING SOON
ATO Approach on Centralised
Operating Models
COMING SOON
ATO Approach on Cross Border RP Financing and Related Transactions
COMING SOON
STPRK
COMING SOON
Providing the clarity, structure and practical guidance you need to support strong tax positions and protect your business against unnecessary disputes.