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    Quantera Global Newsletter – April 2022

    Quantera Global news, developments, and blogs

     

    Quantera Global news, developments, and blogs

    • We are happy to share the hiring of Sneha Jain. Sneha will join our UK team in London as a manager. We look forward to strengthening our existing transfer pricing offerings with Sneha’s strong in-house experience, covering all dimensions of operational transfer pricing and management.
    • On 24 March 2022, a blog was posted on our website about the benefits of a strategic session and the importance of transfer pricing for your company. You can read the blog here.

     

    Quantera Global specialties

    In the past month, we completed several challenging and interesting projects that are worth mentioning, such as:

    • We performed Transfer Pricing “Health checks” for clients, creating clear overviews of the transfer pricing documentation requirements for each country in which they operate. This enabled them to make an informed decision on the steps to take.

    You can read more on this topic here.

    • We advised a client on the centralisation of its treasury function and fully supported them in the implementation of these changes.

    You can read more on this topic here.

    If you would like to know more about these topics, please feel free to contact us.

     

    QG Academy Webinars

    In 2020, we started hosting free-of-charge webinars on a variety of Transfer Pricing topics and we are continuing these webinars in 2022. We currently have the following webinars scheduled:

    • 18 May: Benchmark studies
    • 29 November: Outlook 2023
    • 8 December: Outlook 2023

    To register for one or more webinars, please visit our website https://www.quanteraglobal.com/group-sessions/.

    You can watch our previous webinars here.

    News from around the world:

    Angola

    The Tax Administration in Angola has expanded their list of entities that qualify as ‘’large taxpayers’’. Entities on the list must submit annual transfer pricing documentation to the local tax authorities before the due date of 30 June.

    Denmark

    On 28 March, the Danish High Court rejected the tax administration’s argument concerning a discretionary tax assessment, continuing the reasoning set in recent court rulings. Although there was a basis for conducting the tax assessment, the argumentation of the tax administration was based on an incorrect basis. The case was referred back to the tax authorities for a new assessment.

    Europe

    The Economic and Financial Affairs Council (ECOFIN) met on 15 March. At this meeting, they failed to reach an agreement on the general approach for an EU Minimum Tax Directive. Four member states expressed concerns about the implementation time. A new meeting is scheduled for 5 April 2022.

    Jordan

    The Jordanian Income and Sales Tax Department has now published formal transfer pricing compliance forms on its website.

    OECD

    • On 8 March, the OECD released the comments received on the draft rules for tax base determinations under Pillar One Amount A. The draft rules were released for comments in February 2022.
    • The OECD released further technical guidance on the GloBE Rules on 14 March. The rules are part of the two-pillar solution and elaborate on the application of these rules.

    Peru

    On 26 March, Peru published a legislative decree on profit-sharing association contracts, under which the results of profit-sharing associations are classified as dividends, resulting in a 5% tax on these results.

    Sweden

    On 28 February, the Administrative Court in Sweden ruled in favor of a taxpayer in a case about substance and the capability to carry risk. Summarized, the Administrative Court decided that entities with no employees, given that other intragroup transactions were priced at arm’s length, can still be entitled to more than a risk-free return.

    Switzerland

    On 13 March, Switzerland opened a public consultation on the global minimum tax plan of 15%. As a result of the global minimum tax, Switzerland will probably change its legislation and the consultation is the first step.

    Thailand

    • In March 2022, the Thai Revenue Department published a new template and explanation of the rules regarding the transfer pricing disclosure form. The template and explanation refer to accounting year 2021. The explanation of the rules clarifies, among other things, the definition of a ‘related party’.
    • The deadline for filing the FY 2020 related party disclosure forms has been extended to 30 May 2022.

     

    United Kingdom

    On 17 March, the United Kingdom announced it will stop sharing and exchanging tax information with Russia. This means that Russia will no longer receive information under any of the UK’s exchange of information agreements.

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    We are pleased to share 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.

    Send an e-mail to TPnews@quanteraglobal.com or call us at +31 88 221 5800 and we will introduce you to the relevant professional.