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
- We have launched episode six of our podcast “The Transfer Pricing Method”, titled “How Global Developments and AI Are Shaping the Future of Transfer Pricing”. The episode is now available on Spotify, YouTube, Apple Podcasts and on our website.
- We are delighted to announce that we have been shortlisted for the International Tax Review’s (ITR) EMEA Tax Awards in the “Transfer Pricing Advisory Firm of the Year” category. We are very proud of the continued trust that our clients and partners place in our capabilities.
- On 10 July, we published a case study on streamlining Global Compliance with a Bilateral APA for a family-owned MNE. You can read the case study here.
Quantera Global Specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- Performing a transfer pricing due diligence for a stock quoted company.
- Brainstorm sessions with one of our clients to discuss a new Transfer Pricing policy and related framework.
- Supporting a client during a tax audit, ensuring timely and accurate responses to auditor requests.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Australia
- The Australian Taxation Office has published a new registration form for parent entities that are required to comply with the public country-by-country reporting regime.
- The Australian Taxation Office has released draft guidance on the filing obligations for the Pillar Two Directive. This guidance implements the OECD’s transitional penalty relief framework, summarising the transitional approach and expectations for the Pillar Two filings in Australia.
Bahrain
On 2 July, the National Bureau for Revenue issued a manual on the domestic minimum top-up tax (DMTT) advance payment. The manual outlines the DMTT advance payment process, its functionalities and the related forms.
Denmark
On 1 July, Denmark’s Ministry of Taxation launched a public consultation. The consultation is on a draft bill to implement DAC9 into domestic law. Comments can be submitted until 21 August.
European Commission
On 7 July, the European Commission adopted an Implementing Regulation providing a technical solution for the automatic exchange of top-up tax information return between Member States under DAC9. The objective is to minimise the administrative costs and the burden on taxpayers while complying with their obligations under the Pillar 2 Directive.
European Court of Justice
On 3 July, the European Court of Justice provided clarification on how intra-group services should be valued for VAT. The Court ruled that each service must be assessed separately, even if charged under a single fee. This brings VAT rules into closer alignment with transfer pricing principles.
Kenya
Kenya has enacted its Finance Act 2025, which incorporates various tax measures initially outlined in the Finance Bill 2025. The Act introduces provisions on transfer pricing, including the option for non-resident enterprises to apply for an Advance Pricing Agreement.
Moldova
On 18 July, Moldova published new legislation in the Official Journal. This legislation will take effect on 1 January 2026, amending certain transfer pricing rules. One of the amendments removes the requirement to submit transfer pricing documentation.
OECD
- Ahead of the G20 meeting held in South Africa, the OECD published two reports containing the latest developments in international tax cooperation and transparency.
- On 22 July, the OECD published a second batch of updated country profiles. The updated countries are Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa and Spain. The profiles contain new information on hard-to-value intangibles and Pillar One Amount B.
- On 30 July, the OECD released an XML Schema and an associated User Guide to support the reporting and exchange of information under the Global Minimum Tax rules. The XML Schema enables Competent Authorities to report back whether the information received complies with the validation rules.
Sweden
On 4 July, the Ministry of Taxation in Sweden published a draft memorandum for public consultation. The draft memorandum relates to the implementation of DAC9 into domestic law and proposes that the measures take effect on 1 April 2026. Comments on the public consultation can be submitted until 6 October.
United Kingdom
On 21 July, draft legislation was published, proposing tax measures and amendments, including those relating to the domestic top-up tax. This draft is open for consultation until 15 September.
Final words
Thank you for taking the time to read this edition of our newsletter. I hope you found the insights and updates valuable. Do you have any questions or need further information? Contact us today to get expert advice on worldwide transfer pricing matters and developments.
If you have not already done so, subscribe to our Quantera Global newsletter here and join over 2,000 finance and tax leaders in receiving our newsletter, webinar invitations, latest trends, and sneak peeks into the world of transfer pricing in your inbox every month.
Best regards,
Adriaan van der Heijden
Director at Quantera Global
