News & Blogs
Germany’s Pillar Two Notification Requirement: Approaching Deadline
Germany’s Notification Requirement With the Pillar Two compliance deadline approaching in Germany, multinational enterprises (MNEs) must be aware of their reporting obligations under the Minimum Tax Act. This act requires MNEs within the scope of Pillar Two and operating in Germany to declare which German entity is the head of the minimum tax group by 28 […]
Understanding Pillar One Amount B: Simplifying Global Tax Compliance
In this edition of Transfer Pricing Talks, we explore how Pillar One Amount B simplifies transfer pricing for global businesses. Understanding Pillar One Amount B: Simplifying Global Tax Compliance On 19 December 2024, the OECD/G20 Inclusive Framework on BEPS (“inclusive framework”) released two additional documents on Pillar One Amount B, including fact sheets and Pricing Automation tool. Pillar One Amount B (hereafter also referred to […]
Exploring Brazil’s Transfer Pricing Transformation: OECD TP Guidelines Adoption
The world of international taxation and transfer pricing is ever-evolving, and Brazil has taken a significant step forward by aligning its transfer pricing regulations with the OECD TP Guidelines. In a recent episode of Quantera Global’s podcast, hosted by Adriaan van der Heijden, with insights from Emile Monfils and André Oliveira, the transition and its implications […]
Public Country-by-Country Reporting : A Step Towards Transparency and Accountability
In this week’s transfer pricing talks, we dive into Public Country-By-Country Reporting, a relatively new (transfer pricing) reporting obligation for multinationals. Below, we’ve summarized some points for some light weekend reading. Public Country-by-Country Reporting : A Step Towards Transparency and Accountability The Public Country-by-Country Reporting (“PCbCR”) directive is a key initiative aimed at enhancing transparency and […]
Country-by-Country Reporting in Romania and the Netherlands: Lessons from Early Implementation
Country-by-country reporting (CBCR) has evolved into a cornerstone of tax transparency for multinational enterprises (MNEs). As tax authorities and stakeholders demand greater visibility into financial activities, the European Union’s introduction of public CBCR amplifies these efforts. Romania’s pioneering implementation and the Netherlands’ structured approach reflect the diverse strategies adopted across member states. This blog delves […]
Key Updates on OECD Pillar 1 Amount B from the Netherlands
The Dutch State Secretary for Finance just released important guidance on OECD Pillar 1 Amount B. On 4 December 2024, the Dutch State Secretary for Finance released a Decree in which the consequences of OECD Pillar 1 Amount B for Dutch tax purposes are mentioned. The Decree enters into force on 1 January 2025. OECD […]
Transfer pricing: a critical consideration for Chief Revenue Officers
As a Chief Revenue Officer (CRO), your role encompasses overseeing all revenue-generating functions within your organization. While you may be focused on sales strategies, customer acquisition, and revenue growth, it’s crucial to understand how transfer pricing can significantly impact your responsibilities and the overall financial performance of your company. The intersection of transfer pricing and sales Transfer pricing, which determines the pricing of goods or services […]
Legal form vs. economic substance: examining tax planning strategies
Legal form and economic substance are ideally aligned with each other. If this is not the case, as has historically been the case in some aggressive tax structures, this begs the question what prevails. In this blog we will explain these concepts in more detail and how to deal with this if you would like […]
Optimizing routine sales with group margins below 4%
Understanding the distribution of profits among different entities within a company is crucial. This is particularly important when entities are conducting routine sales but maintain a group margin below 4%. Limited risk distributors, often remunerated with a net operating profit margin of 2-3%, play a key role in this dynamic. However, does this allocation make […]
Italian Transfer Pricing documentation requirements
The Italian tax authorities are considered relatively aggressive in audits and with handing out penalties. Most international tax and transfer pricing professionals are aware of this. The Italian penalty protection documentation is as such something that is often opted for. The requirements to obtain penalty protection are specific. In the following blog, we zoom into these […]