Blogs
Romania Introduces New Transfer Pricing Documentation Requirements under Order 828/2026
Romania has introduced significant changes to its transfer pricing documentation framework through Order 828/2026. The new rules affect documentation thresholds, filing requirements, the content of transfer pricing files and the preparation of benchmarking studies. For large taxpayers in particular, the changes introduce additional compliance obligations, including mandatory annual filing of the transfer pricing documentation file […]
Why Transfer Pricing Policies Fail in Practice
Oliver Treidler, Founder and Managing Director of TP&C and part of the Quantera Global network, shares a practical perspective on a challenge many multinational groups face: creating transfer pricing policies is one thing, but successfully implementing them is something entirely different. Most transfer pricing professionals have experienced it. A policy is designed, intercompany agreements are […]
Transfer Pricing in Practice
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden spoke with Mariia Aspidova, Group Tax Director at Expondo, about the practical challenges in-house tax and transfer pricing professionals face when stepping into a multinational environment. Their discussion covered transfer pricing backlogs, documentation consistency, policy implementation, stakeholder management, and audit readiness. Below are the key takeaways. Transfer […]
Transfer pricing off-pattern: documentation obligations in non‑standard transactions
Polish transfer pricing regulations adopt a broad and sometimes non-obvious approach to defining what constitutes a controlled transaction. As a result, taxpayers in Poland may find that arrangements they would not typically associate with transfer pricing, may, in fact, fall within the scope of documentation and reporting obligations. Transfer pricing is often associated with recurring, […]
VAT and Transfer Pricing: what the Stellantis case means for multinational groups
On 13 May 2026, the Court of Justice of the European Union (CJEU) released its judgment in the Stellantis Portugal case. The case addresses a topic that has been debated for years within multinational groups, transfer pricing teams, and indirect tax specialists alike: Can a transfer pricing adjustment trigger VAT? At first sight, this may […]
Transfer Pricing Controversy Management: How Multinationals Can Prepare for Audits and Reduce Risk
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden spoke with Katrine Ernest Haunstrup of Censio Tax and Emile Monfils of Quantera Global about transfer pricing controversy management. Their discussion explored why transfer pricing audits arise, what makes documentation truly audit-ready, and how multinational groups can better prepare for scrutiny from tax authorities. Below are the key takeaways for tax and finance leaders looking to […]
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 […]