Quantera Global news, developments, and blogs
- We are delighted to have Gareth Green join our team as UK Affiliate. Gareth has over 20 years of transfer pricing experience and is regularly named one of the UK’s leading transfer pricing advisers.
- Quantera Global will host a webinar “Transfer pricing for scale-ups” on 27 March 2024. If you are interested in attending this webinar, follow our LinkedIn profile where we will post updates and the register link to the webinar.
- At Quantera Global, we believe that sharing knowledge is essential. The perfect way to demonstrate this is through the establishment of the QG Academy. The QG Academy was created to share transfer pricing knowledge and build relationships. At our academy, we not only provide webinars and videos on various topics, but also answer the most frequently asked questions on transfer pricing.
- Quantera Global is continuously looking for new talent to join our family. If you are interested in working with us or know someone who is, we recommend you visit our careers page to explore our current opportunities. Should you have any questions about a specific role or are curious about future openings, please don’t hesitate to reach out via email or phone. We are ready to help you in any way we can!
If you would like to know more about these topics, please feel free to contact us.
Quantera Global specialties
In the past month, we have completed several challenging and interesting projects worth mentioning, such as:
- Implementation of a new transfer pricing model for one of our clients, to align their transfer pricing with their growing business.
- Several benchmark studies, which were amongst others used to obtain an Advance Pricing Agreement.
- We performed several financial transactions analyses to substantiate at arm’s length interest rates for intercompany loans.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Algeria
Algeria has enacted two new laws aimed at reducing the tax burden and Transfer Pricing reporting obligations.
Australia
Australia issued exposure draft legislation and supporting explanatory materials on 31 January 2024 that would retroactively update Australia’s transfer pricing legislation to the latest version of the OECD Transfer Pricing Guidelines (incl. the chapter on financial transactions).
France
The French Finance Bill for 2024, enacted on 30 December, introduces several changes to transfer pricing regulations aimed at enhancing tax compliance and control.
Italy
A new Legislative Decree was published on 12 January that requires taxpayers to file their income tax returns within nine months of the end of the financial year, starting from 2 May 2024. This also impacts the transfer pricing documentation timeline, as this reduces the preparation deadline by two months.
Netherlands
On 12 January, the Dutch court fined British American Tobacco €107 million and mandated back taxes due to intentional under-declared profits during the 2013-2016 period.
OECD
The OECD has published statistics from the International Compliance Assurance Program (ICAP), covering completed cases by October 2023. Key findings include completion of 20 cases and longer-than-expected timeframes due to COVID-19.
Poland
The Ministry of Finance published updated its transfer pricing guidance on 29 December 2023, with details on submitting transfer pricing information and transaction specifics. Additionally, a notice effective from 1 January 2024 provides safe harbor interest rates on related party loans, including provisions for contracts in USD or GBP using LIBOR as base rate, which will be discontinued in 2024.
Switzerland
- The Federal Tax Administration of Switzerland has published its safe harbor interest rates for 2024 for loans in both Swiss francs and foreign currencies such as euro and US Dollar.
- The Swiss tax authorities have released an article on transfer pricing, published on 23 January 2024. It covers various aspects of transfer pricing, including legislative basis, interpretation of the arm’s length principle, method selection, and documentation requirements following the OECD guidelines.
United Kingdom
- The UK Government has released its first comments on the feedback received from the public consultation on reforming the UK’s tax law. This new tax law introduces changes relating to transfer pricing, permanent establishments, and Diverted Profits Tax rules to update national tax laws, match global standards, and simplify complexities. The aim is to bring UK rules in line with OECD guidelines, particularly focusing on transfer pricing.
- On 25 January, HMRC published its statistics on transfer pricing and diverted profits tax for 2022-2023. The report highlights significant additional tax revenue and VAT secured through these efforts.
United States of America
The IRS released a legal advice memorandum regarding intragroup loans under section 482. It states that if group membership affects financing terms, even without a formal explicit guarantee, the IRS may adjust the interest rate in controlled lending transactions.