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Quantera Global Newsletter – August 2020

In this Newsletter we would like to keep you up to date on relevant Transfer Pricing developments in an
accessible manner.

We are pleased to keep you informed about 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.
You may 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.

Happy reading and we wish you a safe summer!


Quantera Global news, developments and blogs:

  • TP Risk Assessment Tool
    Our new Transfer Pricing Risk Assessment Tool is now available. The tool consists of 15 questions and provides you automatically with a risk indication of your transfer pricing position and potential practical solutions for the identified risks. Interested? Please take a look at the tool at our website or send an e-mail to info@quanteraglobal.com.
  • Frequently Asked Questions (FAQ)
    The Quantera Global website has been updated with a new page for Frequently Asked Questions. The page provides for answers on basic/general transfer pricing questions and more technical topics within the field of Transfer Pricing. This overview will be updated over time and new topics will be added as well. You can find our FAQ here.
  • Transfer Pricing Developments Germany
    Germany’s new draft law will significantly impact day-to-day transfer pricing. To support our clients and relations on the impact of this new draft law, we have hosted a webinar which included topics such as:

    • German interpretation of the arm’s length principle;
    • Intercompany financing; and
    • Relocation of functions.

You can find the recordings of our webinars here.

Please find below the schedule for our upcoming free webinars:

  • August 18: Brazilian TP/Tax and OECD
  • August 26: Introduction to Transfer Pricing
  • September 22: Developments and Year-End topics
  • October 8: Financial Transactions
  • October 29: IP
  • November 18: Digital Economy
  • December 3: What to expect for 2021

To register for one or more webinars, please send a short e-mail to QGAcademy@QuanteraGlobal.com indicating for which webinar you would like to register.


News around the world:

  • Argentina:
    As a result of challenges that taxpayers may encounter with regard to the COVID-19 pandemic, the Argentina tax authority (AFIP) has released a general resolution that extends the submission deadline for transfer pricing studies and related reports for prior years.
  • Australia
    The Australian tax office published an update of their Transfer pricing rules to align with the OECD transfer pricing guidelines.
  • Belgium:
    The Belgian tax administration released a circular with updated guidance on transfer pricing and BEPS 13 forms, including commentaries on selected topics.
  • Canada:
    In the Canada vs Cameco Corp. transfer pricing case, Canada’s Federal Court of Appeal upholds the decision made in 2018 by the Tax Court of Canada, which ruled in favour of Cameco.
  • DAC6:
    The following countries have opted to defer the reporting deadlines for 6 months regarding the mandatory disclosure requirements (DAC6): Denmark, Ireland, Italy, Luxembourg, Netherlands, Romania, Slovakia, Spain and Sweden.
  • EU:
    • The general court of the European Union decided that the European Commission did not prove that Ireland had granted illegal state aid to Apple via several tax rulings and thus annuls the decision of the commission.
    • The European commission provided non-binding recommendations regarding COVID-19 tax reliefs. These tax reliefs should not benefit companies located in tax havens unless these companies have substantial economic presence, they pay a sufficient amount of tax or make legally binding commitments to remove their ties to tax havens.
  • G20:
    The G20 finance ministers still aim to achieve consensus on pillar one and pillar two before the end of 2020, notwithstanding the current COVID 19 pandemic.
  • Hongkong:
    The Hongkong’s Inland Revenue Department has revised its transfer pricing guidance relating to advance pricing agreements.
  • Oman:
    • Oman deposited its instrument of ratification for the Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting (BEPS). The Multilateral Instrument (MLI) will be entering into force on 1 November 2020.
    • Oman signed the Multilateral Competent Authority Agreement on the exchange of Country-by-Country Reports.
  • Poland:
    • Starting July, video-on-demand (VOD) platforms operating in Poland have to pay an additional levy on their local revenue. This is based on revenues obtained from subscription payments or advertising revenues (depending on which revenue is higher). Some exemptions are included for smaller companies.
    • Poland has issued legislation that postpones the deadline for the preparation of transfer pricing documentation for FY 2019 and for filing the required transfer pricing information forms.
  • Saudi Arabia:
    Saudi Arabia’s General Authority of Zakat and Tax (GAZT) published new guidance on how to make requests under the mutual agreement procedure (MAP).
  • UK:
    The House of Commons passed the Finance Bill for 2020 which included a proposal for a digital services tax. The digital services tax targets the larger digital services companies and imposes a tax rate of 2% on revenue on certain digital income streams connected to UK users.
  • UN:
    The UN Committee of Experts on International Cooperation in Tax Matters adopted new and revised chapters for the United Nations Practical Manual on Transfer Pricing for Developing Countries and approved changes to the UN model tax convention’s commentary. Moreover, new chapters were approved for inclusion in UN handbooks on tax dispute avoidance, resolution and on environmental taxation.
  • USA:
    • The U.S. Treasury Department and IRS released the final regulations concerning the deduction for “foreign-derived intangible income” (FDII) and “global intangible low-taxed income” (GILTI).
    • The IRS published final regulations and additional guidance regarding the limitation on interest deduction. There are exceptions for small businesses with gross receipts below 26 million US dollar and, under conditions, for real estate companies and farming businesses.

This information is intended only as a general update for interested persons and should not be used as a basis for decision-making.
For further details please contact Quantera Global, Eindhovenseweg 128, 5582 HW Waalre,
the Netherlands,
phone: +31 88 221 58 00, e-mail: TPnews@quanteraglobal.com

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