News & Blogs
Romania’s New Transfer Pricing Law: Major Risks Multinationals Must Prepare For
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden spoke with Mihai Lupu (TPS Romania) and Rudolf Sinx (Quantera Global) about Romania’s newly adopted tax on affiliates. Their conversation unpacked the implications of this legislation for multinational groups and outlined practical steps to navigate the shifting regulatory landscape. Below are the key […]
Poland Tightens Transfer Pricing Enforcement: Financing Under the Microscope
This blog was prepared by BTTP, Quantera Global’s Alliance Partner in Poland. It highlights Poland’s tougher transfer pricing enforcement and proposed changes, with a clear focus on intragroup financing and the risk of more audits and higher sanctions. Recent enforcement actions by the Polish National Revenue Administration (“KAS”) demonstrate a clear and accelerating shift toward more aggressive scrutiny […]
Year-end adjustments in transfer pricing: a practical guide
This guide explains year-end adjustments (YEAs) in plain language: what they are, when to use them, what to consider and what to avoid. What is a year-end adjustment? A year-end adjustment (YEA), sometimes called a compensating adjustment, is a correction to intercompany prices or margins to bring a tested party within an agreed arm’s length […]
Transfer Pricing in Transition: How Global Developments and AI Are Shaping the Future of Transfer Pricing
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden sat down with Borys Ulanenko (Arms Length AI) and Maikel Verhoeven (Quantera Global) to discuss how technology, global tax reform, and shifting geopolitics are reshaping transfer pricing. Below are the key highlights and practical takeaways from their conversation, tailored for tax and […]
Germany’s Transfer Pricing Shift: Upcoming Global Implications for Transparency and Compliance
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden welcomes Oliver Treidler and Rudolf Sinx. Together, they explore the evolving landscape of tax audits, compliance demands, and strategic documentation requirements in Germany and the Netherlands. This engaging conversation bridges theory and practice, focusing on actionable strategies for multinational companies. In the […]
Transfer Pricing Forms: Escalating Risks in a Data-Driven Environment
In recent years, tax authorities globally have intensified their focus on transfer pricing (TP) compliance – not solely through traditional audits, but increasingly via comprehensive transfer pricing forms. These structured disclosures, which require taxpayers to report detailed information on intercompany transactions, have become a critical tool enabling tax administrations to conduct data analysis and to […]
Mastering Operational Transfer Pricing: Insights from Industry Experts
Operational Transfer Pricing (OTP) has evolved from being an afterthought to a critical function within multinational enterprises (MNEs). The effectiveness of OTP determines not only regulatory compliance but also financial accuracy, tax efficiency, and overall business stability. In a recent episode of The Transfer Pricing Method podcast, Maikel Verhoeven, Managing Director of Quantera Global, and Stevi Frooninckx, […]
Understanding location-specific advantages: insights from OECD guidelines and UN Model
Location-specific advantages, including location savings are a crucial concept in the field of transfer pricing. They refer to the cost savings and other (beneficial) local market features that multinational enterprises (MNEs) can achieve by relocating their operations to another jurisdiction. What are location-specific advantages? Location savings are the net cost savings MNEs gain by moving […]
Germany’s New Transaction Matrix: What You Need to Know
Starting January 1, 2025, a new component to its transfer pricing documentation requirements have been added in Germany. The transfer pricing regulations in Germany are evolving with the formal implementation of a transaction matrix. This tool will be expected by tax auditors as part of the documentation submitted by companies. This initiative is part of […]
The importance of a well-defined TP strategy
Tax regulations across different countries do not always align, which can result in companies facing double taxation. This can create substantial financial and administrative burdens. A company can partially mitigate this risk by implementing a well-thought-out transfer pricing strategy (policy). In this regard, companies should adhere to several best practices: Conclusion: Navigating the Gray Area of Tax Optimization […]