In this edition of the newsletter, you will find the most important national and global developments in tax law that are (closely) related to the transfer pricing world.
Please feel free to contact us if you have any questions.
Quantera Global news, developments, and blogs
- On 4 November, we published a practical guide for year-end adjustments in transfer pricing. You can read the blog here.
- On 12 November, we published a case study on how to unlock innovation box benefits through strategic R&D alignment for a Dutch MNE. You can read the case study here.
- Our international alliance network is open to new partners. We welcome TP specialists, independent professionals and accounting, audit, tax and legal firms, as well as other like-minded organisations that value quality, clarity and care. You can find more information on this topic here, including a link to schedule an introductory call with us.
Quantera Global Specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- Preparing and submitting FY2024 CbCR reports for several of our clients.
- Preparing a TP-analysis for an e-commerce set-up.
- Requesting an extension of an APA with the Dutch tax authorities.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Australia
- On 3 November, the Australian Taxation Office (ATO) opened consultation on draft guidance for completing the new public CbC report applicable from 1 July 2024. The draft instructions outline four reporting sections covering entity details, jurisdictional entity listings, jurisdiction-specific disclosures, and aggregated information for remaining group members. The consultation was already closed on 28 November 2025.
- The ATO has granted a filing deferral for CbC reporting entities with reporting periods ending on 31 December 2024. This extends the deadline for submitting the Local file, Master file, and CbC report from 31 December 2025 to 30 January 2026. The deferral also applies to entities with replacement reporting periods ending on the same date. Any statements not filed by the new deadline may be subject to penalties.
- The ATO has issued a practical compliance guideline outlining its transitional, “soft-landing” approach to penalties and expectations for the new Pillar Two filing obligations. This offers tailored support and certainty for affected MNE groups during the transition period covering fiscal years beginning on or before 31 December 2026 and ending by 30 June 2028.
Belgium
The Belgian tax authorities have extended the first DMTT return filing deadline to 30 June 2026, in line with the GloBE information return. This replaces the original deadline of 30 November 2025 for the 2024 fiscal year and applies to fiscal years starting on or after 31 December 2023 and ending by 30 June 2025. This is due to the pending return template and the filing portal not yet being available.
Brazil
The following update has been provided by our network partner Castro Barros.
Dividend Taxation Enacted in Brazil: Measure Also Affects Non-Resident Investors, and Uncertainty Regarding 2025 Profit Exemption Raises Legal Concerns
After almost three decades of exemption, Brazil will resume taxing dividends starting in 2026. Bill No. 1,087/2025, approved by the Senate on 5 November, was enacted on 27 November 2025, as Law No. 15,270/2025.
The new law establishes a 10% withholding tax on dividend distributions to individuals when monthly amounts exceed BRL 50,000.
For non-resident investors, the treatment is stricter: a 10% withholding tax applies to any dividend remittance abroad, with exceptions only for sovereign wealth funds, foreign governments, and pension entities.
A significant concern involves the transition rule for 2025 profits. While the law exempts these profits from taxation, the exemption requires corporate resolution by 31 December 2025, a deadline considered unfeasible since year-end results will not yet be finalized. This requirement may trigger administrative and judicial disputes.
The new rules will take effect on 1 January 2026.
Canada
On 4 November, amendments were introduced to modernise Canada’s transfer pricing rules as part of the federal budget. These include a new adjustment rule requiring taxpayers to assess non-arm’s-length cross-border transactions based on both contractual terms and all economically relevant characteristics. The changes are intended to align Canadian transfer pricing standards more closely with the OECD Guidelines. The revised rules and documentation requirements will apply to taxation years beginning after 4 November 2025.
Czech Republic
The incoming government coalition has released a draft tax policy statement proposing amongst others mandatory transfer pricing documentation requirements for MNE groups and a reduction of the corporate income tax rate from 21% to 19%.
European Union
- On 19 November, the European Commission published its second evaluation of the Directive on Administrative Cooperation (DAC). Reviewing its effectiveness across 2018–2023, the evaluation confirmed that the framework remains an efficient and valuable tool for tax transparency and cooperation within the EU. While the evaluation acknowledges progress, it also emphasises the necessity of simplification, greater harmonisation, stronger penalty regimes and better use of data, with a recast proposal expected in Q2 2026.
- On 20 November, the European Commission released its 2025 Taxation and Customs Union Management Plan, which oulines priorities to support the EU’s 2024–29 agenda, including work on a more competitive and sustainable tax mix, VAT and administrative cooperation reforms, energy and environmental tax updates, full CBAM implementation from 2026, ongoing customs modernisation, and the rollout of key initiatives such as ViDA, DAC8/9 and Pillar Two.
Germany
On 13 November, the lower house of parliament approved amendments to the Minimum Tax Act, incorporating recent OECD administrative guidance and simplifying certain anti-profit shifting rules. The upper house of parliament has yet to approve the amendments. The Ministry of Finance has also submitted draft measures on DAC9 implementation and updates to treaty and PE rules.
Israël
On 2 November, the Israel Tax Authority (ITA) finalised its Circular outlining conditions under which local R&D centres can retain cost-plus treatment, limiting challenges by ITA exam teams when specified criteria are met. The Circular also establishes a seven-year ruling framework for post-acquisition IP sales, requiring timely transfer of IP, minimum valuation thresholds, and confirmation of the reduced 6% capital gains rate.
Italy
On 7 November, a Ministerial Decree set out the filing and payment obligations for Italy’s Pillar Two top-up tax. It confirmed that the Pillar Two tax return is due on the same timeline as the GloBE information return: 15 months after the fiscal year end, or 18 months for the first year of application.
Kenya
On 3 November, the Kenya Revenue Authority issued draft regulations establishing an advance pricing agreement regime. This allows taxpayers to agree transfer pricing methodologies and at arm’s length pricing in advance. There are options for bilateral and multilateral APAs and rollback provisions. The proposal also includes information on application and renewal fees and annual compliance obligations.
Liechtenstein
On 7 November, Parliament approved Pillar Two amendments introducing an additional registration requirement for Liechtenstein entities filing the GloBE information return. This return is due 15 months after year-end (18 months in the transition year).
OECD
- On 5 November, the OECD published an updated list of jurisdictions that have signed the GIR MCAA (Multilateral Competent Authority Agreement) for the automatic exchange of GloBE information under Pillar Two. This list now includes Austria, Belgium, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Japan, South Korea, Liechtenstein, Luxembourg, the Netherlands, New Zealand, Norway, Portugal, Slovakia, South Africa, Spain, Switzerland and the United Kingdom.
- On 19 November, the OECD released an update to the OECD Model Tax Convention, introducing detailed guidance on short-term cross-border remote work and new provisions ensuring income from natural resource extraction is taxed where the activity occurs. The update also includes further refinements aimed at enhancing consistency in treaty interpretation and strengthening overall tax certainty.
- At the November 2025 South Africa Summit, the OECD presented its Secretary-General Tax Report to G20 Leaders, highlighting progress on BEPS minimum standards, the Two-Pillar solution and tax transparency. This report also noted that the Inclusive Framework is advancing technical work on the G7’s proposed “side-by-side” tax arrangement. The G20 Leaders’ Declaration reaffirmed a commitment to continued engagement on concerns around Pillar Two with the aim of reaching a balanced and practical global solution.
Poland
The following update is provided by our network partner BTTP.
Recent actions by the Polish National Revenue Administration indicate a significant intensification in transfer pricing enforcement, particularly with regard to intragroup financing. This is illustrated by a recent PLN 11.5 million adjustment on non-market bond interest. The Ministry of Finance has announced a new strategy focused on aggressive tax planning, including a competence centre in Kraków, increased data-driven audits and planned legislative tightening by the end of 2025. A draft CIT/PIT amendment submitted to Parliament introduces public TP disclosures, publication of aggregated TP data, higher sanction rates and mandatory audits every three years for large taxpayers. Together, these measures indicate a significantly tougher audit environment with financial transactions emerging as the highest-risk area.
Romania
The Ministry of Finance has issued an ordinance amending the Pillar Two rules under Law No. 431/2023 to align with the OECD Model Rules and EU Directive. These updates introduce clearer tax credit definitions, refined pension entity rules, and adjustments to excess profit and tax rate calculations.
Singapore
On 19 November, the Inland Revenue Authority of Singapore (IRAS) released the eighth edition of its Transfer Pricing Guidelines. This introduces updates on the treatment and annual review of domestic related-party loans, IRAS’ ability to recharacterize or disregard funding arrangements, simplified transfer pricing documentation, and the pilot implementation of Amount B under Pillar Two.
United Kingdom
HMRC has issued new guidance for compliance teams on settling transfer pricing enquiries where a taxpayer’s filed position is outside the arm’s length range and double tax relief may be available through MAP. In such cases, HMRC’s default position is to adjust to the central point of the range (typically the median). Proposals for settlements using a different point in the range will generally be rejected unless they are supported by strong technical justification.
Final words
Thank you for taking the time to read this edition of our newsletter. I hope you found the insights and updates valuable. Do you have any questions or need further information? Contact us today to get expert advice on worldwide transfer pricing matters and developments.
If you have not already done so, subscribe to our Quantera Global newsletter here and join over 2,000 finance and tax leaders in receiving our newsletter, webinar invitations, latest trends, and sneak peeks into the world of transfer pricing in your inbox every month.
Best regards,
Adriaan van der Heijden
Director at Quantera Global
