Context and Background
In 2024, Quantera Global was engaged by a major US-headquartered multinational enterprise (MNE) operating in over 50 countries with an annual turnover exceeding 10 billion USD. The client, an industry leader with three significant business units, faced rising pressures from increasing tax scrutiny, operational complexity, and compliance burdens related to transfer pricing (TP).
The mandate was to lead a global TP redesign, ensuring consistency, transparency, and alignment across all business units (BUs), while mitigating the risk of double taxation and enabling long-term compliance efficiency.
Quantera Global’s Role and Strategic Contribution
Appointed as the global TP advisor, Quantera Global:
- Redesigned the TP policy for all three BUs to reflect business realities and BEPS-compliant practices.
- Localized the TP policy across approximately 40 jurisdictions, coordinating closely with the client’s internal teams.
- Oversaw a group-wide review of global QBCs (Quality Business Cases) and tax reporting, ensuring risk alignment.
- Supported the integration of TP automation software to streamline documentation and compliance processes globally.
This complex engagement was spearheaded by Rudolf Sinx and Theo Elshof, supported by Adriaan van der Heijden (Director) and a globally integrated team. Their leadership ensured strategic clarity and deep technical grounding.
Strategic Challenges
- A highly complex multinational structure across numerous jurisdictions.
- Significant potential for double taxation, particularly due to inconsistent local TP interpretations.
- Need to balance strategic tax planning with operational implementation across three diverse BUs.
- Compressed timelines – under one year – to deliver both global design and localization.
- Coordination with an in-house team managing a range of internal systems and external obligations.
Outcome delivered
Quantera Global delivered a successful transformation by:
- Completing the end-to-end TP policy redesign, localization, and reporting refresh in under 12 months.
- Aligning global business objectives with tax compliance across 50+ countries.
- Enabling proactive TP risk management through automation and centralized oversight.
- Equipping the client to navigate growing regulatory complexity with scalable, auditable solutions.
Why This Matter Was Significant
This project was a flagship global TP transformation because:
- It was conducted for a large, business-driven MNE with high exposure to tax risk.
- The project mitigated future double taxation risks by ensuring jurisdictional alignment at every level.
- It reflected Quantera Global’s ability to integrate strategy, execution, and technology into a unified TP framework.
- The engagement demanded precision, speed, and innovation – hallmarks of Quantera Global’s advisory ethos.
Ready to unify your global TP with speed and certainty?
Quantera Global helps complex multinationals implement BEPS-aligned policies, localize across dozens of jurisdictions, and embed automation to reduce double taxation risk and lower compliance burdens. We deliver with the pace and precision your business demands. Whether you are redesigning group-wide TP, coordinating localization across multiple business units, or scaling documentation and reporting, we guide you from strategy to execution.
Let’s discuss your global TP priorities. Contact us here.