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    Quantera Global Newsletter – August 2022

    Quantera Global news, developments, and blogs

    Quantera Global news, developments, and blogs

    • On 14 July, Quantera Global hosted a webinar on the transfer pricing aspects of financial transactions. We discussed the latest developments in this field and provided tips on how to be prepared for potential audits. You can find the recording of the webinar here.

    Quantera Global specialties

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

    • We hosted a strategic session and provided in-depth considerations on a solid transfer pricing model for the future. You can read more about our strategic sessions.
    • We assisted a start-up company in setting up its operations in the Netherlands by performing a transfer pricing analysis and determining the most appropriate transfer pricing method.

    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:

    • 29 November: Outlook 2023
    • 8 December: Outlook 2023 (2)

    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:

    European Commission
    The European commission opened a consultation on 6 July on tackling the role of enablers of tax evasion and aggressive tax planning. The initiative aims to focus on the enablers who create these complex and non-transparent structures. It is possible to submit feedback until 12 October 2022.  

    Germany
    Germany published its draft implementation bill for DAC7 on 12 July. EU Member States must transpose the draft legislation for DAC7 into national law by 31 December 2022. The first year to be reported on is 2023.

    Hungary
    A bill containing new transfer pricing rules passed the Hungarian Parliament on 19 July. Intercompany transactions will have to meet significant additional reporting obligations and if a transfer pricing adjustment is made, the price will have to be adjusted to the median.

    Kenya
    Kenya has introduced new transfer pricing filing requirements starting from the 2022 financial year. The requirements are contained in the Finance Act 2022. The reporting requirements apply to entities of multinationals and include a Country-by-Country report, master file and local file.

    Luxembourg
    Luxembourg has published draft legislation regarding DAC7. Platform operators that fulfill the reporting requirements must register by 31 December 2023. The deadline for the first reports is extended to 31 January 2024.

    OECD

    • On 28 June, the OECD published 19 new arbitration profiles. The profiles contain information on the application and the country’s position regarding the BEPS multilateral instrument.
    • On 11 July, the OECD invited public comments on the Progress Report on Amount A of Pillar One. The comments will be used to further develop the technical design of Amount A. Comments can be submitted until 19 August 2022.

    Poland
    On 5 July, a ruling was issued concluding that a Polish entity has no reporting or transfer pricing documentation obligations for a transaction consisting of a contribution to a foreign company’s supplementary capital.  

    The Netherlands

    • In the Netherlands, a bill has been submitted that implements an EU directive regarding profit tax disclosure. Multinationals and independent companies with more than €750 million revenue or consolidated income must publish a separate annual income tax report. The aim is to provide more transparency on the profit tax payments by multinationals.
    • As also mentioned in our previous newsletter, an updated version of the Dutch Decree on Transfer Pricing and an updated version of the Dutch Decree on profit allocation permanent establishments were published on 1 July.

    United Kingdom

    • On 20 July, the UK government released for consultation the draft legislation regarding the Finance Bill 2022/23. The draft legislation covers announced and unannounced proposals and comments can be submitted until 14 September 2022.
    • The draft legislation published on 20 July also contains new transfer pricing documentation requirements. The new requirements will apply to large businesses (turnover above €750 million) and follow the OECD Transfer Pricing Guidelines.
    • The released draft legislation also contains the Income Inclusion Rule of Pillar Two. The multinational top-up tax is the implementation of the OECD GloBE Model Rules.
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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.