Quantera Global Newsletter – December 2022 Schedule a call

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    Quantera Global Newsletter – December 2022

    Quantera Global news, developments, and blogs

    • On 7 December, NOB’s TP section hosted a PE program on the transfer pricing decree and other current affairs with our colleague Rudolf Sinx as chairman of the day. Together with delegates from the Ministry of Finance and the Tax Administration, we look back on a very successful and inspiring seminar. We welcomed 120 participants, with many NOB members on the reserve list. We may therefore host this PE session again in the future. 
    • On 10 November, Quantera Global organised the third edition of the Master Minds on Tax and Technology at BCD Travel´s headquarters. This interactive edition focused on Transfer Pricing and Treasury technology. 
    • On 14 November, Quantera Global published a blog regarding the OECD BAPA manual. You can find our blog here. 
    • On 23 November, Quantera Global published a blog on intercompany services. Our blog can be found here 
    • Last week, Quantera Global employees received a Rotary International ‘End polio now’ tulip package. Polio is a disease that is still prevalent in parts of the world. Most of the proceeds will go to the ‘End Polio Now’ charity. For Every package sold, the Bill and Melinda Gates Foundation triples the amount.  
    • We are hiring! An overview of our vacancies can be found here 

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

    Quantera Global specialties

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

    • We assisted a medium-sized multinational in selecting the most appropriate transfer pricing model for its local operations worldwide. 
    • We are currently preparing, together with our client, the request to be filed with the Dutch tax authorities for the application of the Dutch innovation box in view of the client’s innovative activities. 

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

    QG Academy Events & 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:  

    • 19 December: Top 10 critical TP-issues from an Indian and Dutch perspective. 

    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:

    On 8 November, the Argentine Commission on Foreign Affairs approved the bill ratifying Multilateral Instrument to implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting. 

    The Chinese tax authority has published its annual advance pricing arrangement report for 2021. This report includes details and statistical data on the Chinese APA programme. 

    Court of Justice of the European Union (“CJEU”)
    On 8 November, the CJEU issued a judgment in the case: Fiat Chrysler Finance Europe v. Commission. The CJEU annuls the decision of the General Court to accept the Illegal State aid analysis by the European Commission. According to CJEU, the used reference framework by the European Commission to apply the arm’s length principle to integrated companies in Luxembourg, was incorrect.  

    European Union
    On 8 November, European Union finance ministers agreed on a revised code of conduct for corporate taxation to identify and curb harmful tax measures of Member States. 

    On 10 November, the German Bundestag adopted the law on the implementation of DAC7 (EU Council Directive 2021/514). DAC7 relates to the mandatory provision of information by some digital platforms to tax authorities. 

    On 18 November, Malta published legislation implementing formal transfer pricing rules. The transfer pricing rules will be effective from 1 January 2024. 

    On 2 November, the Ministry of Finance published guidance on transfer price determination methods and transfer pricing documentation. 

    An updated ATAD 2 Decree regarding the application of the Dutch anti-hybrid mismatch legislation has been published.  

    On 9 November, 28 jurisdictions signed international tax agreements to exchange information on income earned from digital platforms and offshore financial assets.
    On 16 November, the OECD received public comments on the Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One.
    On 22 November, the OECD released the latest statistics on the mutual agreement procedure (MAP) covering 127 jurisdictions and virtually all MAP cases worldwide. 

    United Arab Emirates (“UAE”)
    The UAE Ministry of Finance published the issuance of a new Federal Decree Law (No. 28 of 2022) on Tax Procedures. The new Federal Decree Law repeals Federal Decree Law No. 7 2017. Major changes include an obligation to file a voluntary disclosure, adjustments to some definitions and the timeframe for the Federal Tax Authority to notify the taxpayers of upcoming tax audits. 

    United Kingdom
    On 17 November, the Autumn Statement was published. The Autumn Statement includes future tax proposals, such as: increase of corporate taxation and increase of diverted of profit tax by 1 April 2023 and the requirement for large MNEs operating in the UK to keep and retain transfer pricing documentation in a prescribed and standardised format in line with the OECD Transfer Pricing Guidelines. 


    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.