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    Quantera Global Newsletter – February 2022

    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.

    Quantera Global news, developments, and blogs:

    Quantera Global specialties

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

    • Renewed transfer pricing design and established a process for the integration of companies being acquired and related attention points
    • Performed a toll manufacturing benchmark including several comparability adjustments for an APA process
    • Supported clients in audit processes
    • Supported clients in obtaining innovation box rulings

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

    Two new blogs on our website

    • On 31 January, we posted a blog on our website on the OECD Guidelines 2022 and the implications for your organisation.
    • On 1 February, another blog was posted on our website. In this blog Stefan Ubachs, Director at Quantera Global, describes the Dutch legislation on the elimination of mismatches when applying the arm’s length principle and highlights some examples.


    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:

    • 4 February: UAE corporation tax and Transfer Pricing
    • 8 February: Transfer Pricing documentation & Coperitas (transfer pricing software)
    • 14 April: Transfer Pricing and Financial Transactions
    • 18 May: Benchmark studies
    • 29 November: Outlook 2023
    • 8 December: Outlook 2023

    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 around the world:


    On 12 January, it was announced that the Australian Taxation Office will review its advance pricing arrangement (APA) programme in 2022, focusing on, among other things, on whether the programme assures TP risk in the most efficient manner.


    As of 1 January 2022, the arm’s length corporate profit tax interest rate on related-party loans is 2.68% per annum instead of 3.00% per annum. As such, the maximum (deductible) interest rate paid by a Croatian entity and the minimum taxable interest rate charged by  a Croatian entity that provides a loan decline as well.


    On 24 January, the Cyprus Tax department published a series of ‘’frequently asked questions’’ (FAQ’s) regarding the tax treatment of intra-group back-to-back financing transactions.


    Under recent tax reform measures, Maquiladora companies will no longer be able to use an advance pricing agreement (APA) as a mechanism for resolving transfer pricing issues from January 2022.


    A set of tax amendments was adopted in Montenegro and published on 31 December 2021. The amendments include a new definition of related parties, transfer pricing compliance guidelines and an expansion of the list of methods used for assessment of prices in line with the arm’s length principle.


    On 4 January 2022, the Federal Inland Revenue Service published a notice withdrawing an earlier notice. The earlier notice suspended the requirements for Nigerian resident branches and subsidiaries of foreign MNEs to file CbC-reports in Nigeria. With the withdrawal of the suspension order, the constituent entities are expected to comply with the CbC filing requirements from 1 January 2022.


    On 20 January, the new OECD transfer pricing guidelines were published. This is the first update in five years. The OECD made three significant additions and revisions to the guidelines. These changes address guidance on the transfer pricing aspect of financial transactions, the transactional profit split method, and hard-to-value intangibles.


    On 1 January, the rules for reverse hybrid entities went into effect. The rules include a new reporting obligation, including the deadline for reporting.


    • On 10 January 2022, the Swiss State Secretariat for International Financial Matters published a report containing Switzerland’s views on tax and transfer pricing developments (Pillar II, MAP procedures and tax treaty negotiations).
    • The Swiss Federal Council decided on 12 January 2022 that it will implement the 15% global minimum tax via a constitutional amendment, in accordance with the OECD Inclusive Framework. This amendment will come into force on 1 January 2024.


    The United Arab Emirates’ Ministry of Finance announced on 31 January the implementation of a federal corporate tax regime at a standard 9% rate. The new corporate tax regime will become effective to relevant businesses from June 2023. We have hosted a webinar on this topic on 4 February. Please send an e-mail to QGAcademy@quanteraglobal.com if you wish to receive further input.

    United Kingdom

    • On 11 January, the UK government launched a consultation on how it plans to implement and administer the OECD model rules on the 15% global minimum tax in the UK. Potential wider amendments to the base erosion and profit shifting (BEPS) measures will also be considered in the consultation.
    • The UK government launched a consultation on revised draft guidance for the upcoming uncertain tax treatment notification requirement for large businesses on 18 January.



    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.