Context and Background
In early 2025, Quantera Global advised a family-owned multinational enterprise (MNE) with over €100 million in annual revenue. The client runs a vertically integrated value chain covering development, production, and sales, and is active in more than 20 jurisdictions across the globe.
The company faced challenges implementing appropriate transfer pricing (TP) corrections from its principal location due to the structure of its IT systems and the centralization of warehousing operations. To resolve this, the client pursued a Bilateral Advance Pricing Agreement (BAPA) between the jurisdiction of the principal and the jurisdiction where the primary warehouse was located.
Quantera Global’s Role and Strategic Contribution
Maikel Verhoeven, supported by Adriaan van der Heijden (Director), led Quantera Global’s efforts to:
- Structure and negotiate a BAPA with both jurisdictions involved.
- Ensure all TP corrections could consistently be executed from the warehousing location.
- Secure routine TNMM remuneration for warehousing, production, sales, and invoicing hub activities.
By engaging early and pragmatically with tax authorities, the team helped the client secure a robust, future-proof agreement that aligns with operational realities and tax compliance needs.
Strategic Challenges
- BAPAs are rare and often avoided due to perceived cost and time investment.
- The client’s IT constraints limited how TP corrections could be operationalized from the principal entity.
- Reaching a consensus across two jurisdictions with differing administrative expectations required careful alignment of both legal and factual positions.
Outcome delivered
Quantera Global successfully:
- Obtained a full BAPA within one year, covering all intended corrections and functions.
- Delivered certainty and tax risk mitigation, especially concerning future audits.
- Demonstrated a practical solution to a common MNE issue, blending technical accuracy with operational feasibility.
Why This Matter Was Significant
This engagement stood out due to its strategic relevance and complexity:
- It showed that BAPAs can be efficient when planned and executed pragmatically.
- It set an example for how IT and operational challenges in TP can be addressed with early alignment across jurisdictions.
- It highlighted Quantera Global’s strength in cross-border negotiation and tailored structuring, reinforcing the firm’s leadership in high-value TP advisory work.
Facing Complex TP Challenges Across Jurisdictions?
Quantera Global helps multinational businesses navigate the technical and operational hurdles of cross-border transfer pricing. From negotiating BAPAs to aligning TP execution with IT and operational constraints, our tailored solutions deliver certainty and practical results, quickly and effectively.
Ready to make your TP strategy future-proof?
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