News & Blogs
Quantera Global Newsletter – January 2025
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 and Developments Quantera Global Specialties In the past month, several challenging and noteworthy projects were successfully completed, including: If you […]
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 […]
Advance Pricing Agreements in Italy
We are pleased to highlight our ongoing collaboration with MUSE Strategy as a member of the Quantera Global Network. This long-term strategic partnership aims to provide valuable insights and updates on international tax and transfer pricing regulations in the particular example zooming into Italy. As part of this collaboration, we are pleased to share their […]
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 […]
Pillar One, Amount B: “The rise of the secret comparables?”
On 17 July 2023, the OECD/IF published the public consultation document for Pillar One, Amount B. The objective of this consultation document is to simplify the pricing of baseline marketing and distribution activities, to increase tax certainty for businesses, and to minimise conflicts between taxpayers and tax administrations. Unlike Pillar Two, there is no revenue threshold […]
Comparability analysis: more than only a benchmark study
A comparability analysis is an essential part of any transfer pricing analysis. Its purpose is to obtain an in-depth understanding of the significant characteristics of the controlled transaction and the roles of the respective parties involved which is needed in determining and substantiating the arm’s length remuneration of a controlled transaction. Performing a comparability analysis consists of […]