Ristevski, 55, showed no emotion as he was sentenced to a maximum of nine years' prison in Melbourne's Supreme Court on Thursday morning.

Outside court, Karen's brother Stephen Williams made a brief statement: "We didn't get justice today, at all."

The couple's daughter Sarah Ristevski, who has become estranged from her mother's side of the family, was also at the courthouse to hear her father's fate.

Ristevski has not told police how or why he killed his 47-year-old wife in their Avondale Heights home in Melbourne's north-west on June 29, 2016.

Justice Christopher Beale said Ristevski's conduct after he killed Karen, including dumping her body in bushland, carrying her coffin at her funeral and spinning a web of deceit about her death, was a significant aggravation.

"You have finally accepted responsibility for killing Karen [but] you have not revealed how or why you have killed your wife," Justice Beale said.

"You have not taken the high road of full and frank disclosure consistent with true remorse."

Ristevski could have been jailed for up to 20 years for manslaughter.

Justice Beale said the possibility of closure for her family was complicated, if not cruelled, as they will never know how Karen died.

He quoted from the victim impact statement of Karen's aunt Patricia Gray: "If Borce could do anything for Karen it would be for him to take away the constant stream of images of Karen struggling for her last breath ... the not knowing is worse than knowing."

Justice Beale said their daughter, Sarah, was the principal victim after Karen. He said out of love, Sarah did not submit a victim impact statement and instead provided a character reference for her father.

"I mean no criticism of Sarah - anyone with a modicum of compassion would understand her predicament is an agonising one," he said.

Police believe Ristevski killed his wife between 8.58am and 10.43am on the day she went missing and drove her body in her black Mercedes-Benz to Mount Macedon, more than 50 kilometres away, and dumped her remains between two logs.

Karen's remains were not found until a bushwalker stumbled upon her shallow grave in Macedon Regional Park on February 20, 2017, eight months after she went missing.

Investigators believe the couple argued about the financial plight of their clothing business, Bella Bleu, beforehand.

Ristevski was charged with murder in December 2017 after a lengthy police investigation, involving listening devices and analysis of CCTV footage.

In March, Justice Beale ruled that evidence about Ristevki's behaviour after Karen's death could not prove murderous intent.

Ristevski instead pleaded guilty to the lesser charge of manslaughter after months of repeatedly lying to his daughter, family members and the police about what he did that day and denying having any involvement.

In a glowing character reference she wrote for her father five days after he pleaded guilty Sarah said he was a "good dad and husband".

"I have so many amazing memories with my dad that I will forever cherish, especially those memories of my parents together," she wrote.

"The love they had for each other and the marriage that they shared is something I hope to one-day experience myself.

"He would always put my mum and I first before anyone else, as did my mum with him and I.

"The circumstances have left me without both of my parents, and I know there is nothing that I can do to change that but all I can try to do is communicate the truth of how good of a dad and husband he was to my mum and I."

SMH/The Age