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
- Quantera Global is delighted to announce the appointment of Adriaan van der Heijden as Managing Director at Quantera Global, as of 1 January 2026. You can read the full press release here. Additionally, Jade van Veelen has been promoted to Manager at Quantera Global with effect from the same date.
- On 9 December, we published a blog with our alliance partner BTTP on Poland’s tougher transfer pricing enforcement. You can read the full blog here.
- Our international alliance network is open to new partners. We welcome transfer pricing specialists and independent professionals, as well as accounting, audit, tax, and legal firms, and other like-minded organisations that value quality, clarity, and care.
You can find more information here, including an option to schedule an introductory call with us.
Quantera Global Specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- Preparing, reviewing, and submitting FY2024 CbCR reports.
- Financial transaction analyses, including a cash pool analysis, interest rate analysis and intermediary financing analysis.
- A transfer pricing compliance analysis for a large multinational operating in over 40 countries.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Argentina
On 16 December, AFIP published a General Resolution, updating TP regimes for fiscal periods ending on or after 31 October 2025. The Master file transaction threshold has been set at ARS 100bn with related-party thresholds of ARS 150m/15m, and the simplified regime cap has risen to ARS 3bn with aligned related-party thresholds. Procedures have been updated, including a new Form 2673 for Master file filings or a ratification note where there are no changes.
Australia
On 10 December, the ATO released draft changes to the TP guidance for inbound distributors and invited comments by 13 February. The new TP guidance will reduce EBIT profit markers for Life Sciences (categories 1–2) and ICT, define when digital sellers qualify as inbound distributors (excluding those operating significant hosting equipment), remove references to pre-qualified unilateral APA pathways, update the view on value-creating activities with profit-split cases out of scope, and add a “white zone” for arrangements covered by an APA or high-assurance review in the past three years.
Bahrain
On 25 December, the National Bureau for Revenue (NBR) published an updated VAT deregistration manual that outlines the revised process with step-by-step guidance. It explains when deregistration is required, how to apply via the NBR portal, and what evidence and timelines are involved. The NBR also updated its Domestic Minimum Top-Up Tax (DMTT) FAQs to reflect current filing and procedural points for in-scope groups.
Belgium
On 7 December, the Belgian government approved a package of tax measures. These tax measures are intended to simplify compliance and strengthen fraud detection. Under the new transfer pricing measures, MNEs will no longer be required to proactively file transfer pricing studies in Form 275 LF (Local File). However, they are still obliged to indicate the existence of such documentation on the form, and they are still able to add the transfer pricing studies in section C1 of the form if it benefits their storyline.
Brazil
The Administrative Council of Tax Appeals (CARF) has ruled that payments under international cost-sharing agreements are not subject to Brazil’s CIDE tax on royalties and technical services. The decision clarified that CIDE only applies to payments for specific technology or technical services, and not to expense allocations between related entities. CARF concluded that cost-sharing agreements are mere reimbursements without profit intent and therefore do not trigger CIDE liability. The ruling was published in early December 2025.
Colombia
The Supreme Administrative Court ruled in Decision No. 27844 that DIAN cannot use a debt transaction as a comparable for related-party deposit agreements, given that the agreements differ in terms of purpose, term, and currency. Furthermore, the taxpayer’s rates were found to be in line with those of domestic market deposits. The Court also confirmed that freight costs must be deducted from LME-based ferronickel prices to determine FOB Cartagena pricing.
Croatia
On 5 December, the Croatian Parliament adopted a bill amending the country’s Pillar Two rules. This requires the DMTT to be calculated using financial statements prepared under the ultimate parent’s accounting standard, unless this would cause practical difficulties. The amendments came into force eight days after publication in the Official Gazette.
Denmark
The National Tax Tribunal recently ruled in favour of the Danish tax authorities. In this case, a company transferred intangible assets to a new group company. Following the transfer, the company performed routine functions relating to the transferred intangible assets to the new group company. While the Danish tax authorities found that proper TP documentation was in place, the transfer price was not at arm’s length. The National Tax Tribunal agreed with the Danish tax authorities, stating that when using a Discounted Cash Flow valuation, the return requirement for routine functions should be similar to the return requirements for the entire business. As the company used different return requirements, the transfer price was considered not to be at arm’s length.
European Union
- On 11 December, the European Commission announced that it had closed infringement procedures against Spain, Cyprus, Portugal, Lithuania, Estonia, Greece, Poland, and Latvia for failing to transpose the EU Minimum Tax Directive. All EU Member States were required to implement the directive by 31 December 2023. Proceedings began in January 2024 for non-notification of national measures.
- On 12 December, ECOFIN approved its H2 2025 tax-progress report. It noted a lack of progress on BEFIT, advancing a decluttering and simplification agenda, and confirming plans to withdraw the Financial Transaction Tax and the Unshell, DEBRA, and Transfer Pricing Directive proposals. It also covers clean-tech tax incentives, Pillar Two “Side-by-Side” and talks with Norway on broader direct-tax information exchange.
- On 12 December, ECOFIN separately approved the Code of Conduct Group conclusions. These covered the monitoring of local measures and special economic zones, the EU list of non-cooperative jurisdictions and defensive measures, and ongoing work on beneficial-ownership transparency and CbCR follow-ups.
France
- On 3 December, the tax authorities issued guidance on transition aspects of France’s Pillar Two rules. This clarifies the treatment of pre-regime deferred tax attributes, the handling of intra-group asset transfers before GloBE applies, and the use of the initial phase of international activity exclusion. Additional guidance is being drafted on safe harbours, effective tax rate and top-up tax calculations, charging mechanisms, and filing and payment.
- The Conseil d’État upheld the decision of the French tax authorities in a recent court case. The French tax authorities found that the company had borne expenses for the benefit of foreign subsidiaries, notably staff secondment and IT costs, that were not reimbursed. The tax authorities considered these costs to be hidden distributions subject to withholding tax. Although the company did reintegrate the amounts into its taxable income, the authorities still upheld the characterization as advantages granted without consideration. The Conseil d’État confirmed that indirect benefits such as preserving subsidiary solvency or increasing share value were not valid consideration and that the amounts paid for the Chinese subsidiary were taxable in France as other income rather than dividends under the France-Chinese tax treaty.
Hungary
On 2 December, the Ministry for National Economy published a draft decree on transfer pricing documentation and data disclosure. The decree aims to align with the OECD Guidelines, reduce administrative burdens, and strengthen audit readiness. It raises thresholds, mandates benefit tests and fuller DEMPE analysis for intangibles, simplifies low value-adding services with a 5% mark-up, and requires segmented operating profit statements by activity.
Ireland
On 18 December, the Revenue Commissioners issued an e-Brief extending the Pillar Two registration deadline to 28 February 2026 (rather than 31 December 2025) for groups with a 1 January–31 December 2024 fiscal year. In-scope Irish constituent entities must make a one-time online registration via ROS for IIR, UTPR and/or QDMTT, even if no top-up tax is due; an agent may register on their behalf. Revenue also clarified treatment for dissolved, inactive/dormant entities, and entities without an active tax registration.
Netherlands
Following Lower House adoption in November, the Upper House approved the 2026 Tax Plan package on 16 December, including Pillar Two changes and DAC9 implementation.
Poland
The following update has been provided by our network partner BTTP.
Poland continues to intensify tax enforcement, expanding focus from transfer pricing documentation to withholding tax (“WHT”) and tightening regulatory expectations for intragroup financial transactions.
- Two cases published by the Polish National Revenue Administration (KAS) in December 2025 reinforce the priority placed on withholding tax compliance (here and here). These cases signal stronger audit focus on beneficial ownership, economic substance, and proper verification of relief at source as well as proper transfer pricing benchmarking studies.
- Updated transfer pricing reporting rules (TPR) entered into force in December 2025 and will apply to reporting periods beginning after 31 December 2024. The amendments adjust methodologies and data structures to align with revised accounting terminology and financial indicator (formal publication can be found here).
- On 10 December 2025, the Ministry of Finance and Economy issued an announcement formalising benchmark base reference interest rates and arm’s-length margins for related-party loans, effective 1 January 2026, for applying the safe harbour mechanism in intragroup loan transactions.
MNEs should proactively:
- Review cross-border payment flows and verify WHT exemption entitlement;
- Update Master and Local Files and TPR reporting methodologies ahead of 2025 filing deadlines;
- Adjust especially intragroup loan benchmarking to reflect the newly published parameters; and
- Align tax, treasury, and accounting governance to support audit readiness.
Turkey
On 1 December, the tax administration extended the QDMTT filing deadline for fiscal years ending on 31 December 2024 to 15 January 2026. E-filing is not yet available, but a test environment has been launched for familiarisation and questions. In order to file, a group must appoint and register a local designated filing entity for QDMTT purposes.
United Arab Emirates
On 30 December, the Federal Tax Authority has introduced an Advance Pricing Agreement programme under the UAE corporate tax regime to provide advance certainty on transfer pricing arrangements. The programme aligns with OECD transfer pricing standards. At the initial stage, it is limited to unilateral APAs and generally applies to controlled transactions with an aggregate value of at least AED 100 million per tax period, covering 3 to 5 prospective tax periods. The procedural framework is set out in the FTA Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1), which is an administrative guidance and not legally binding. The programme applies to tax periods commencing on or after 1 January 2024.
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
Managing Director at Quantera Global
