Depends on a lot of things, like how the dealership is laid i.e. are service, their holding yard, the pre-delivery department and sales on completely different sites? The cars will have a trade plate fitted, and driven between them as needed, likewise, if you've asked for a full tank of fuel. Not many dealerships have on-site bowsers anymore. Will it need to go off-site for accessories, such as tint? Are you buying it off the lot, or is it a special order? If it's been at the the dealership for a while, chances are it will have been demo'd with prospective buyers.

Taking all those things into consideration, it's very rare to see a car being delivered with a single digit odometer reading. They usually have a handful of k's on them when they lob in off the truck, having been driven around between the production plant, the docks, the ship, the holding yards, and the car carriers.

Having worked at dealerships for over 10 years, I would think it would be reasonable to expect that a specifically-ordered brand new car could have maybe up to 20kms on the clock at the most, by the time you take ownership.