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Quantera Global Newsletter – August 2021

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.

Quantera Global news, developments, and blogs:

Family businesses

Family businesses are of great importance to the (Dutch) economy. More and more family businesses are expanding business abroad. As such transfer pricing challenges and issues may arise. Therefore, family businesses will be highlighted by Quantera Global in the next couple of months. Stay tuned for more information and articles on this subject.

Quantera Global specialties

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

  • We concluded an Advance Pricing Agreement (APA) with the Dutch Tax Authorities on a complex business with multiple transactions including a profit split.
  • We determined an arm’s length compensation for a cross-border transfer of IP in view of a contemplated change of the client’s business model.
  • Analysis and support with the implementation of a client’s cash pool structure. This included setting the arm’s length margins to be applied and the set-up of appropriate allocation and monitoring tools for the cash pool.
  • We assisted a client cost-efficiently and effectively with Transfer Pricing compliance in 15+ jurisdictions with support of software solution Coperitas.

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

QG Academy Webinars

Last year we started hosting free-of-charge webinars on a variety of Transfer Pricing topics and we are continuing these webinars in 2021. We currently have the following webinars scheduled:

  • 26 August: Time to save Budget & Time
  • 9 September: Transfer Pricing Risk Management: APAs & MAPs

To register for one or more webinars, please visit our website https://www.quanteraglobal.com/group-sessions/ and select the webinar you would like to register for.

You can watch our previous webinars here.

News around the world:

  • European Commission

On July 14, the General Court of the European Union dismissed the action brought by Nike to annul the European Commission’s formal investigation procedure in respect of tax rulings issued by the Dutch tax authorities to Nike’s Dutch holding company.

  • Germany

On July 14, the German tax authorities published new administrative principles for transfer pricing, which are more in line with the OECD Transfer Pricing Guidelines.

  • Gibraltar

The CIT rate in Gibraltar will increase by 2.5% to 12.5% for accounting periods beginning after 20 July 2021.

  • Iceland

Administrative penalties will be imposed for legal entities not documenting their related party transactions. For companies with income or assets worth over ISK 1 billion (approx. EUR 6.7 million) it will be mandatory to have transfer pricing documentation in place.

  • The Netherlands

The Dutch Supreme Court has concluded in a long-awaited ruling that the Dutch Tax Authorities correctly denied interest deductions of a company based on ‘fraus legis’ (abuse of law). In this case, an artificial financial construction was set-up with no specific business purpose. The only goal of the construction was to avoid taxes.

  • Oman

The tax authorities of Oman have suspended the local CbCR filing requirement for MNE groups with their ultimate parent established outside Oman. Nevertheless, the notification requirement should still be respected.

  • Poland

The Polish government has published new draft tax legislation (for public consultation) regarding, amongst others, the extension of transfer pricing documentation deadlines and new exemptions for transfer pricing documentation

  • United Arab Emirates

The Ministry of Finance of the UAE has issued guidance on the Mutual Agreement Procedure (MAP) to assist taxpayers to resolve tax and transfer pricing disputes.